Dennis L. Martin v. Barnesville Exempted Village School District Board of Education

Citations: 209 F.3d 931; 10 Am. Disabilities Cas. (BNA) 787; 2000 U.S. App. LEXIS 7206; 2000 WL 425914Docket: 99-3263

Court: Court of Appeals for the Sixth Circuit; April 21, 2000; Federal Appellate Court

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Dennis L. Martin appealed the summary judgment favoring the Barnesville Exempted Village School District Board of Education regarding his claim of discrimination based on a perceived disability (alcoholism) under the Americans with Disabilities Act (ADA) and Ohio Revised Code. Martin, employed as a bus driver since 1984, was observed drinking beer on duty in 1991, leading to disciplinary actions that included a proposed termination for violating the school’s drug-free workplace policy. After union intervention, he signed a "Last Chance Agreement," which required him to acknowledge a drinking problem, complete rehabilitation, serve a suspension, and comply with drug testing for two years, which he did without incident.

In December 1994, despite being the most senior applicant, Martin was denied part-time bus driver and garage worker positions due to the prior incident. He filed a grievance, and an arbitrator ruled in his favor, stating the school board failed to prove he posed a safety threat. The board's subsequent appeal to the Belmont County Common Pleas Court resulted in the arbitration award being vacated, but this was later reversed by the Ohio Court of Appeals, reinstating the arbitrator's decision. Ultimately, the appellate court affirmed the district court's judgment, concluding that no ADA violation occurred since Martin's employment issues stemmed from his misconduct rather than perceived disability discrimination.

The Court of Appeals reversed the Court of Common Pleas, stating that an arbitrator's award is to be upheld unless it has "no connection" to the labor contract. The arbitrator had balanced safety and seniority concerns appropriately, and the state court could not overturn the decision based on disagreement with the outcome. The Ohio Supreme Court denied a discretionary appeal from the defendant. The plaintiff was awarded the positions he sought by December 1994 and began work in February 1998, but he did not receive back pay or other remuneration for lost wages. He filed a suit under federal and state disability discrimination laws in September 1997 while arbitration was ongoing. Both parties argued that the arbitration did not bar review of the plaintiff's federal claim. The court noted that since the plaintiff was awarded the positions sought, his request for those roles was moot, leaving the issue of whether he should receive compensatory and punitive damages for alleged discrimination. 

To succeed in a disability discrimination claim, the plaintiff must show he was disabled under the ADA, qualified for the job, suffered an adverse employment action, and was replaced by a nondisabled person. If he establishes a prima facie case, the burden shifts to the employer to provide a legitimate, nondiscriminatory reason for the action. The plaintiff must then demonstrate that this reason is a pretext for discrimination. The ADA prohibits discrimination against qualified individuals with disabilities in employment. The plaintiff does not assert a physical or mental impairment but claims to be "disabled" based on either a record of impairment or being regarded as such. The district court granted summary judgment to the defendant, ruling the plaintiff failed to show his condition substantially limits major life activities. The current court affirmed this decision on different grounds, emphasizing the distinction between adverse job actions due to misconduct versus those based solely on disability.

An assistant football coach at the University of Tennessee was terminated following a DWI arrest. He contended that his alcoholism constituted a disability under the Americans with Disabilities Act (ADA) and argued that his impaired driving was a consequence of this disability, thus preventing his dismissal. The court assumed, without affirming, that alcoholics can be considered individuals with disabilities under the ADA. However, it clarified that the ADA allows employers to enforce the same performance standards for alcoholic employees as for others, regardless of whether misconduct is linked to alcoholism, as specified in 42 U.S.C. 12114(c)(4). 

The case referenced, Maddox, was pivotal, as the plaintiff had previously acknowledged his "drinking problem" in a Last Chance Agreement. The defendant denied the plaintiff's applications for bus driver and garage worker positions due to a prior drinking incident at work. The court supported the defendant’s position, emphasizing that the law does not obligate them to hire someone with a history of drinking on the job, particularly in a role that poses a risk to children. It argued that requiring the school board to employ such an individual would create significant legal and moral liabilities if an accident were to occur. The court concluded that even if the plaintiff established a prima facie case of discrimination, the defendant presented a legitimate, non-discriminatory rationale for their actions, which the plaintiff failed to prove was a pretext for discrimination. Consequently, the district court's decision was affirmed.