Murphy v. United Parcel Service, Inc.

Background

A UPS mechanic had a long history of very high blood pressure that, when untreated, was medically severe but when treated with medication generally left him able to function. UPS required mechanics to be able to drive commercial motor vehicles and meet Department of Transportation (DOT) medical standards. The mechanic was initially and mistakenly certified, but after retesting UPS concluded he did not meet DOT standards and fired him. He sued under the Americans with Disabilities Act (ADA), claiming he was disabled or was “regarded as” disabled.

Reasoning

The Court focused on two questions: whether a person’s condition must be judged while using medication, and whether UPS “regarded” him as substantially limited in working. Relying on its prior decision in Sutton, the Court held that the medicated state is the appropriate baseline for deciding whether an impairment substantially limits major life activities. The Court also found that UPS’s decision reflected a belief that the mechanic could not meet DOT driver rules for that specific driving duty, not a belief that he was precluded from a broad class of jobs. Because he was employable in many mechanic jobs that do not require DOT certification, the Court concluded he was not disabled or regarded as disabled under the ADA.

Real world impact

The ruling lets employers consider whether a medical condition is controlled by treatment when deciding if someone is disabled and allows safety-related DOT medical standards to justify denying specific driving duties. The decision is not a final answer to every medical side-effect or unmedicated limitation claim; it leaves questions about residual or medication side-effect limitations for other cases.

Dissents or concurrances

Justice Stevens, joined by Justice Breyer, dissented and would have found the mechanic disabled based on the severity of his unmedicated hypertension, and would have sent the case back for further proceedings.