Moskal v. Delphi Automotive System, Inc.
Docket: No. 02-3887
Court: Court of Appeals for the Sixth Circuit; May 6, 2003; Federal Appellate Court
Edward L. Moskal appeals a district court ruling that dismissed his civil rights complaint under the Americans with Disabilities Act (ADA), claiming discrimination due to his disabilities: hemifacial scapular muscular dystrophy (MD) and Alopecia Universalis. Moskal, employed as a contract worker at Delphi Automotive Systems, underwent a physical examination and drug screening as part of the hiring process. Despite his conditions, which he argued required reasonable accommodation in the form of a urine drug test instead of a hair sample, the district court found that his Alopecia Universalis did not qualify as a disability under the ADA. The court noted that Moskal failed to demonstrate how his conditions limited major life activities or how he was discriminated against based on his MD. The appellate court affirmed the summary judgment, reiterating that to prove disability discrimination, Moskal needed to show he had a disability as defined by the ADA, which he did not. He acknowledged that his condition did not hinder his ability to perform essential job functions or major life activities. Therefore, the court concluded that Moskal could not establish a prima facie case of disability discrimination, affirming the district court's judgment.