Parker v. Crete Carrier Corp.

Obstructive sleep apnea was a condition that caused individuals to intermittently stop breathing during sleep. Untreated, obstructed sleep apnea caused daytime sleepiness, leading to impaired driving skills and increasing the risk of motor-vehicle accidents. A sleep study was the only way to determine whether a person suffered from obstructive sleep apnea, and an in-lab study was the most reliable method of analysis. Individuals with a high body mass index (BMI) were the most likely to have the condition. The Department of Transportation (department) required commercial-vehicle drivers to get medical examinations to determine whether they were physically qualified to drive. The department recommended that drivers with high BMIs undergo an additional sleep study to determine whether they suffered from obstructive sleep apnea. Crete Carrier Corporation (Crete) (defendant) began requiring its drivers with high BMIs to undergo in-lab sleep studies. Robert Parker (plaintiff) was a commercial driver for Crete with an excellent driving record and no history of sleep issues. However, Parker registered a high BMI during his physical examination, and Crete’s policy required Parker to participate in an in-lab sleep study. Parker went to his primary physician and received a note saying that a sleep study was not necessary, but Crete refused to exempt Parker from the study requirement. Parker refused to undergo the sleep study, and Crete stopped giving Parker work. Parker filed suit in federal district court, alleging that Crete’s sleep-study requirement violated the Americans with Disabilities Act (ADA). The district court granted summary judgment to Crete, and Parker appealed to the Eighth Circuit.