Employment -Eighth Circuit Rules That An Injured Employee Who Could Not Obtain Required Medical Certification Could Not Perform An Essential Job Function

In Knutson v. Schwan’s Home Service, Inc., No. 12-2240 (8th Cir. 2013), the plaintiff, Jeffrey D. Knutson (“Knutson”), had brought suit against the defendant , Schwan’s Home Service, Inc.(“Home Service”), alleging that Home Service had terminated his employment in violation of the Americans with Disabilities Act (the “ADA”). The district court had granted summary judgment to Home Service, and Knutson appealed.

In this case, Knutson had been manager at Home Service, who was sometimes required to drive a delivery truck. As to his truck driving responsibilities, Home Service’s position description states that Knutson must meet the Federal Department of Transportation (“DOT”) eligibility requirements, including obtaining an appropriate driver’s license and a corresponding medical certification (an “MEC”). Knutson suffered a penetrating eye injury, and thereafter was unable to obtain an MEC or waiver thereof. Home Service later fired him. This suit ensued.

In analyzing the case, the Eighth Circuit Court of Appeals (the “Court”) said that, to establish a prima facie case under the ADA, Knutson was required to show that he was disabled within the meaning of the ADA, was qualified to perform the essential functions of his job, and suffered an adverse employment action because of his disability. The Court determined that Knutson was not qualified to perform his job’s essential functions. No genuine issue of material fact exists that being DOT qualified to drive a delivery truck is an essential function of Knutson’s position. The Home Service position description indicates that such qualification is an essential job function. Since he could not obtain an MEC after the eye injury – and therefore was not DOT qualified after the injury – he was not qualified to perform an essential job function. As such, the Court affirmed the district court’s summary judgment in Home Service’s favor