Leonel v. American Airlines, Inc.

Three California residents, Walber Leonel, Richard Branton, and Vincent Fusco (plaintiffs) (the applicants), applied separately to work as flight attendants at American Airlines, Inc. (American) (defendant) in 1998 and 1999. American flew each applicant to Dallas, Texas for interviews. At the end of each interview, American offered each applicant employment that was conditioned upon completing a drug test, a medical examination, and a background check. American then directed each applicant to American’s medical department to submit to a medical examination. Although all three applicants had human immunodeficiency virus (HIV), none of the applicants disclosed his HIV-positive status or listed HIV medications on any forms. American’s nurses drew blood samples from each applicant. A few days later, American asked each applicant to explain anomalies in his blood testing. At that point, each applicant disclosed his HIV-positive status. American’s recruitment department then rescinded each applicant’s job offer, claiming that the recruitment department was unaware of the applicant’s medical status and that American did not tolerate lies or intentional factual omissions in the application process. Branton and Fusco sued American separately in California state courts, and Leonel sued American in federal district court; all three applicants alleged that American had violated the Americans with Disabilities Act (ADA) and state law. American removed Branton’s and Fusco’s cases to federal district court based on diversity jurisdiction. American moved for summary judgment, arguing in part that American’s recruiting department had not evaluated the medical-examination results until after it had completed background checks. The district court consolidated the three applicants’ cases and granted American’s summary-judgment motion. The applicants appealed.