Williams v. Fedex Corporate Services
849 F.3d 889
| 10th Cir. | 2017Background
- Williams, a FedEx salesperson, took medical leave in Sept. 2011 for severe anxiety, neck pain, and Suboxone withdrawal after treatment for prescription opioid dependence; he filed a short-term disability claim with Aetna.
- Aetna approved benefits but categorized his condition as a “Chemical Dependency,” limiting benefits to 13 weeks, and notified FedEx that Williams filed a claim for substance abuse.
- FedEx, relying on Aetna’s report and its Alcohol/Drug Free Workplace Policy (ADFWP), required Williams to contact an employee assistance vendor (People Help), sign a Statement of Understanding, submit to return-to-duty drug testing, join a five-year follow-up testing program, and disclose prescription-medication use as a condition to return to work.
- Williams submitted medical/provider letters and a People Help assessment showing no current substance abuse diagnosis; he returned to work in Feb. 2012 and later resigned in 2014.
- Williams sued under the ADA (failure-to-accommodate/hostile work environment; regarded-as disabled; and improper medical inquiry/required medical examination under §12112(d)(4)(A)) against FedEx, and for ERISA fiduciary breach against Aetna; the district court granted summary judgment for defendants.
- The Tenth Circuit affirmed in part, reversed in part, and remanded: it affirmed dismissal of Williams’s ADA discrimination and regarded-as claims and Aetna ERISA claim, but reversed/remanded the ADA §12112(d)(4)(A) (disability-related inquiry/medical examination) claim for the district court to address whether FedEx improperly required prescription-disclosure and whether any business-necessity defense applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did FedEx discriminate under ADA based on Williams’s actual disability (anxiety/adjustment disorder)? | Williams: supervisors berated him, refused workload relief, blocked transfer, disciplined him — actions exacerbated his diagnosed anxiety and impaired major life activities. | FedEx: most adverse acts occurred before it knew of his anxiety; no evidence actions were because of disability. | Affirmed — Williams failed to show FedEx knew of his disability or took adverse action because of it; no prima facie case. |
| Did FedEx regard Williams as disabled (perceived as drug addict) and thereby discriminate? | Williams: Aetna’s report led FedEx to treat him as substance abuser, impose testing and monitoring — discriminatory. | FedEx: acted under neutral policy in good-faith reliance on Aetna’s report; mandatory measures were nondiscriminatory. | Affirmed — FedEx articulated legitimate reason and Williams failed to show pretext; summary judgment valid. |
| Did FedEx violate ADA §12112(d)(4)(A) by requiring medical examinations/disability-related inquiries (e.g., disclosure of prescription meds)? | Williams: FedEx required disclosure of prescribed medications and enrollment in drug-testing program as a return-to-duty condition — improper inquiry/medical examination absent job-related necessity. | FedEx: drug policy targets illegal drug use and ensures workplace safety; Williams consented; business necessity justified measures. | Reversed in part and remanded — triable issue exists whether requiring disclosure of prescription medications was an improper inquiry; district court must consider business-necessity defense and factual disputes. |
| Did Aetna breach ERISA fiduciary duties by classifying Williams’s claim as Chemical Dependency and reporting substance-abuse claim to FedEx? | Williams: Aetna mischaracterized his claim (stress/anxiety) and wrongfully reported substance-abuse claim to FedEx, causing harm. | Aetna: records and Williams’s own statements indicated Suboxone withdrawal/addictive use; plan authorized reporting to employer; decision not arbitrary and not a fiduciary breach. | Affirmed — Aetna’s determination and reporting were reasonable under arbitrary-and-capricious review and consistent with plan terms and vendor reporting obligations. |
Key Cases Cited
- Bryant v. Farmers Ins. Exch., 432 F.3d 1114 (10th Cir.) (summary judgment standard and view of evidence)
- Koessel v. Sublette Cty. Sheriff’s Dep’t, 717 F.3d 736 (10th Cir.) (ADA disability definitions)
- EEOC v. C.R. Eng., Inc., 644 F.3d 1028 (10th Cir.) (McDonnell Douglas framework in ADA cases)
- Penry v. Fed. Home Loan Bank of Topeka, 155 F.3d 1257 (10th Cir.) (hostile work environment standard)
- Nat’l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (U.S. Supreme Court) (factors for hostile work environment analysis)
- MacKenzie v. City & Cty. of Denver, 414 F.3d 1266 (10th Cir.) (causation requirement in ADA claims)
- Sandoval v. City of Boulder, 388 F.3d 1312 (10th Cir.) (ADA causation analysis)
- Johnson v. Weld Cty., 594 F.3d 1202 (10th Cir.) (pretext standard — employer’s good-faith belief focus)
- Roe v. Cheyenne Mountain Conference Resort, Inc., 124 F.3d 1221 (10th Cir.) (ADA §12112(d)(4)(A) medical-inquiry analysis)
- Eugene S. v. Horizon Blue Cross Blue Shield of N.J., 663 F.3d 1124 (10th Cir.) (public access to records and arbitrary-and-capricious review guidance)
- Krohn v. Huron Mem’l Hosp., 173 F.3d 542 (6th Cir.) (fiduciary duty to provide complete and accurate information)
- Adair v. City of Muskogee, 823 F.3d 1297 (10th Cir.) (business necessity exception for medical inquiries)
- Bates v. Dura Auto. Sys., Inc., 767 F.3d 566 (6th Cir.) (factors for determining improper medical inquiry vs business necessity)
- Colony Ins. Co. v. Burke, 698 F.3d 1222 (10th Cir.) (standard for sealing judicial records)
- AST Sports Sci., Inc. v. CLF Distribution Ltd., 514 F.3d 1054 (10th Cir.) (treatment of sealing requests for medical/confidential records)