Maddox v. University of Tennessee

Robert Maddox (plaintiff) was employed as an assistant football coach for the University of Tennessee (UT) (defendant). As part of the hiring process, Maddox submitted an application stating that he had no health problems that would limit his ability to perform his duties and no criminal arrest record. However, Maddox was an alcoholic and had been arrested for possession of a controlled substance and driving a motor vehicle while under the influence. While working at UT, Maddox caused a publicity scandal for being arrested again for driving under the influence and for inappropriate behavior. Maddox attended an alcohol rehabilitation program after his arrest, and UT placed him on administrative leave. UT discovered Maddox’s past record and terminated his employment, stating that termination was necessary due to Maddox’s arrest, misconduct, bad publicity, and UT’s determination that Maddox was no longer qualified for his coaching position. UT claimed that it did not know about Maddox’s alcoholism and that the alcoholism did not factor into the termination. Maddox filed suit in federal district court, claiming that UT unlawfully terminated him due to discrimination based on his alcoholism in violation of the Rehabilitation Act and the Americans with Disabilities Act (ADA). Maddox claimed that his misconduct was related to his alcoholism and that by using the alcoholism-related conduct as a basis to terminate him, UT based its termination on his disability. The district court granted summary judgment for UT, finding that the school did not discharge Maddox solely because of his disability. Maddox appealed to the Sixth Circuit.