Chandler v. City of Dallas

The City of Dallas (city) (defendant) implemented a driver-safety program creating physical standards for city employees classified as primary drivers, who drove on public roads as part of their job duties. The standards were taken from the United States Department of Transportation and the Federal Highway Administration. Two of the physical standards stated that primary drivers could not be insulin-dependent diabetics or have less than 20/40 corrected vision in each eye. The federal standards that set these requirements for insulin use and vision had not changed for several decades, despite multiple reevaluations. Lyle Chandler and Adolphus Maddox (plaintiffs) were city employees who did not meet the primary driver standards for their positions. Chandler required insulin to control his diabetes and had failed a driver’s physical examination due to his condition. Chandler also had several documented hypoglycemic episodes while on the job. Maddox failed his initial driver’s physical examination because of his vision, which could not be corrected to meet the primary driver standard. Chandler and Maddox filed suit against the city in federal district court, claiming that the primary driver standards for insulin use and corrected vision violated the Rehabilitation Act. The district court ruled in favor of Chandler and Maddox, and the city appealed to the Fifth Circuit.