Equal Employment Opportunity Commission v. Hussey Copper Ltd.
United States District Court for the Western District of Pennsylvania
696 F. Supp. 2d 505 (2010)
- Written by Alexander Hager-DeMyer, JD
Facts
Donald Teaford (plaintiff) applied for a production-laborer position at a mill run by Hussey Copper Ltd. (Hussey) (defendant). All of the available production-laborer positions were safety sensitive. At the time of his application, Teaford was recovering from prior drug addiction, and his treatment included prescribed doses of methadone, a well-established medication used in narcotic withdrawal. Hussey issued Teaford a conditional employment offer, pending a physical and drug test. During his physical examination, Teaford provided a urine sample but failed to disclose his use of methadone or his treatment for narcotic dependency. The urine tested positive for methadone, and Dr. Daniel Nackley reviewed the result with Teaford over the phone. Nackley asked about Teaford’s methadone use but did not have a cognitive-ability test administered or inquire about Teaford’s cognitive function with anyone who had treated or examined Teaford. Nackley did not examine Teaford directly or contact Teaford’s treating physician for a consultation. Based on his experience, Nackley recommended that Hussey prevent Teaford from taking any safety-sensitive tasks due to Teaford’s methadone use, claiming that the drug impaired cognitive function and that Teaford would pose a health and safety risk. Nackley stated that the standard of care for methadone users was to deny them safety-sensitive work. Because Teaford was not eligible for any safety-sensitive work, Hussey withdrew Teaford’s employment offer. The Equal Employment Opportunity Commission (EEOC), on behalf of Teaford, filed suit against Hussey, alleging violations of the Americans with Disabilities Act (ADA). At trial, the EEOC produced expert testimony that methadone users like Teaford typically stabilized after extended monitored use and did not pose safety risks. Additionally, national scientific literature stated that controlled use of methadone did not impair cognitive functions and had no adverse effects on functionality or employability.
Rule of Law
Issue
Holding and Reasoning (Fischer, J.)
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