Samson v. Federal Express Corp.
874 F. Supp. 2d 1360
M.D. Fla.2012Background
- FedEx seeks summary judgment on ADA and FCRA claims by Richard Samson, who has Type I diabetes.
- Samson claimed he is disabled and was denied employment after failing a DOT medical exam and being unable to obtain a CDL.
- Technicians at FedEx Floridian ramps must be DOT-qualified and hold a current medical certificate due to vehicle weights exceeding 26,001 pounds.
- FedEx’s job description for Technicians includes mandatory DOT medical exam and CDL, applicable to interstate and intrastate commerce.
- The DOT regulations require insulin-dependent diabetics to be physically unqualified to drive a commercial motor vehicle in interstate commerce.
- Samson’s conditional offer was revoked after his failed medical exam; he did not pursue the DOT diabetes exemption program.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Samson is a 'qualified individual' with a disability | Samson argues he could perform essential functions with accommodation. | Samson cannot perform essential functions because he cannot obtain DOT certification. | Samson not a qualified individual; DOT rules bar qualification. |
| Whether DOT regulations provide a complete defense to ADA claims | DOT standards should not bar ADA liability; exemptions may be available. | DOT medical and CDL requirements are a complete defense to the ADA claims. | DOT regulations provide a complete defense; no ADA violation. |
| Whether a reasonable accommodation was available | FedEx could have accommodated Samson or kept the position open for exemptions. | No accommodation could work without violating federal law or creating liability. | No reasonable accommodation existed. |
Key Cases Cited
- Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555 (1999) (DOT standards preempt or limit ADA liability when applicable)
- Holly v. Clairson Indus., L.L.C., 492 F.3d 1247 (11th Cir. 2007) (elements of a prima facie ADA race)
- Knutson v. Schwan’s Home Service, Inc., 870 F. Supp. 2d 685 (D. Minn. 2012) (DOT regs as defense to ADA claims when job-related)
- Murphy v. United Parcel Service, Inc., 946 F. Supp. 872 (D. Kan. 1996) (driving as essential function of mechanic in interstate commerce context)