Owusu-Ansah v. Coca-Cola Co.

Beginning in 1999, Franklin Owusu-Ansah (plaintiff) worked for Coca-Cola Co. (defendant) at a call center. In December 2007, Owusu-Ansah told his manager that several coworkers had discriminated against him and harassed him because he was from Ghana. According to Owusu-Ansah’s manager, Owusu-Ansah banged his fist on the table, raised his voice, and said someone would “pay for this.” Owusu-Ansah later declined to speak with Coca-Cola’s senior human-resources manager about his concerns. However, Owusu-Ansah agreed to speak with Dr. Marcus McElhaney, an independent consulting psychologist specializing in crisis management and threat assessment. McElhaney believed that there was a strong possibility that Owusu-Ansah was delusional and recommended a fitness-for-duty evaluation. Coca-Cola placed Owusu-Ansah on paid leave and required him to undergo a fitness-for-duty evaluation with psychiatrist Dr. Christopher Riddell. Owusu-Ansah met with Riddell but initially refused to discuss his employment issues. After Coca-Cola warned Owusu-Ansah that he would be terminated unless he cooperated, Owusu-Ansah completed the evaluation. Dr. Riddell cleared Owusu-Ansah to return to work in April 2008. Owusu-Ansah then sued Coca-Cola, arguing that Coca-Cola had violated the Americans with Disabilities Act (ADA) by compelling Owusu-Ansah to complete the evaluation. The district court granted Coca-Cola’s motion for summary judgment, holding that the evaluation did not violate the ADA. Owusu-Ansah appealed.