Transportation Executive Summary: Eighth Circuit Affirms Dismissal of ADA Claims In Transportation Case Regarding CDL Accommodations

09.11.2026

Summary:

The United States Court of Appeals for the Eighth Circuit has upheld a ruling from the District Court for the Eastern District of Arkansas – Central, holding that the district court did not err in its analysis regarding Plaintiff’s failure to produce evidence that his atrial fibrillation actually substantially limited his major life activities, and that his requests for general safety equipment were not ADA accommodation requests.

Facts:

This case involves a truck operator for United States Environmental Services, LLC (“USES”), who alleged disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act (ACRA). The Plaintiff worked as a truck operator and was required to maintain an active Commercial Driver’s License (CDL). After refusing to perform work usually done by technicians (cleaning underground tanks) due to an alleged lack of protective gear and safety equipment, and after disclosing that he had a heart condition, USES required him to undergo a medical exam. After the exam, USES placed a temporary 45 day medical hold on Plaintiff’s CDL. Although medically cleared for all non driving duties, USES declined to let him work in any capacity during the hold. The Plaintiff resigned at the end of the 45 days and filed suit.

Procedural History & Lower Court Rulings:

Donald Stephens (Plaintiff) sued his former employer under the ADA, ACRA, and FLSA. The district court dismissed Plaintiff’s FLSA claim. On the ADA/ACRA claims, the district court granted summary judgment on behalf of USES because the Plaintiff had not shown that his atrial fibrillation substantially limited any of his major life activities, therefore it was not a disability. No medical provider testified that he had difficulty breathing, troubling episodes, or any functional limitation at the relevant time. Further, USES did not perceive him as disabled. Additionally, his complaints and request for a respirator while completing the task were found to be related to general workplace safety, not an ADA accommodation based on disability; therefore, he had not engaged in protected activity by requesting the respirator. The Plaintiff appealed to the Eighth Circuit, challenging the disability discrimination and retaliation summary judgment rulings.

Analysis & Appellate Arguments

Under the ADA, someone is disabled if they have “a physical or mental impairment that substantially limits one of more major life activities.” 42 U.S.C. § 12102(1)(A). Plaintiff argued that his atrial fibrillation was a qualifying disability because the condition may substantially limit one’s breathing, cardiovascular functioning, blood flow and more. Additionally, Plaintiff argued that his refusal to clean tanks without a respirator was, in effect, a request for reasonable accommodation, which is a protected activity; and USES retaliated against him when it restricted him from working and created conditions leading to his resignation. Heisler v. Metro. Council, 339 F.3d 622, 632 (8th Cir. 2003) (requesting an accommodation is a protected activity). He also argued that, alternatively, USES perceived him as disabled due to the employer-completed medical exam and CDL hold.

Regarding the disability claim, USES argued that Plaintiff produced no evidence of any actual substantial limitation affecting him, personally, at or near the time of the events. The USES nurse who completed the medical exam, and Plaintiff’s cardiovascular doctor, both indicated he had no symptoms, such as troubling episodes or shortness of breath, and he was fit for all work except driving during the medical hold. Regarding the retaliation claim, USES argued that Plaintiff’s request for a respirator was a safety request, not a disability based accommodation request; thus, it was not protected activity under the ADA. Lastly, USES raised the fact that the Plaintiff resigned voluntarily after refusing alternative options (including short term disability).

The Eighth Circuit held that the Plaintiff could not rely on the general medical diagnosis and symptoms of atrial fibrillation to qualify as disabled; he needed evidence showing how he personally was substantially limited — and he had none. Therefore, his disability discrimination claim failed. Further, the Court agreed with USES that the Plaintiff’s request for a respirator was not an ADA accommodation: it was part of general safety protocol applicable to all workers, which Plaintiff asked about because he thought it necessary for the task he was directed to do. As he was not seeking an accommodation for a disability, but only seeking a safety precaution available to all, he did not engage in ADA protected activity and his retaliation claim also failed.

The Eighth Circuit’s decision reinforces two important ADA principles. First, diagnosis alone is not enough. To prove disability, an employee must show how their condition substantially limits their own major life activities. Generic medical descriptions do not suffice without individualized evidence. Second, safety complaints are not ADA accommodation requests. To be a protected activity, an accommodation request must be tied to the employee’s disability and essential job functions, not ordinary workplace safety concerns.

Ultimately, because the Plaintiff lacked evidence of actual functional limitations and because his respirator request was related to safety rather than disability, his discrimination and retaliation claims could not survive summary judgment. The district court’s judgment was therefore affirmed.