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Morriss v. BNSF Railway Co.

817 F.3d 1104 (2016)

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Morriss v. BNSF Railway Co.

United States Court of Appeals for the Eighth Circuit

817 F.3d 1104 (2016)

Facts

BNSF Railway Company (BNSF) (defendant) offered Melvin Morriss (plaintiff) a position as a machinist. Because BNSF considered the machinist position to be safety-sensitive, the offer was contingent on a satisfactory medical review. BNSF doctors conducted two physical examinations of Morriss. At one examination, Morriss weighed 285 pounds and had a body mass index (BMI) of 40.9, and at the other, he weighed 281 pounds, which resulted in a BMI of 40.4. Morriss reported that he considered his overall health to be good, and treatment records provided by Morriss’s doctor indicated that he was not suffering from any physical impairment. BNSF, however, had a policy that precluded the hiring of a new applicant for a safety-sensitive position if the applicant’s BMI was equal to or exceeded 40. BNSF revoked Morriss’s employment offer, and Morriss filed suit under the Americans with Disabilities Act (ADA). Morriss argued, among other things, that BNSF discriminated against him because it regarded his obesity as a disability. The district court entered summary judgment in favor of BNSF, and Morriss appealed.

Rule of Law

Issue

Holding and Reasoning (Wollman, J.)

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