Shirley v. Precision Castparts Corp.

726 F.3d 675 (2013)

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Shirley v. Precision Castparts Corp.

United States Court of Appeals for the Fifth Circuit
726 F.3d 675 (2013)

  • Written by Alexander Hager-DeMyer, JD

Facts

Bryan Shirley (plaintiff) worked for Wyman-Gordon Forgings, L.P. (Wyman-Gordon) (defendant), a subsidiary of Precision Castparts Corporation (defendant). Shirley regularly took Vicodin, a prescription painkiller, as prescribed by his doctor for work-related injuries. However, Shirley developed an addiction to the painkillers, seeking multiple prescriptions from multiple doctors and abusing the dosages. Wyman-Gordon policies stated that any employee with a drug problem could confidentially inform the company’s human resources (HR) department to seek treatment. However, an employee who rejected treatment or left a treatment program prior to being properly discharged would be terminated. After a near overdose, Shirley requested leave from Wyman-Gordon, and the HR department granted Shirley’s request so that he could seek treatment. Shirley checked into a recovery center to begin treatment. A full treatment plan consisted of an initial detoxifying stage and a second step of treatment to address the need for prescription drugs. Shirley completed the detoxifying but checked out before the second step. Days after leaving the treatment center, Shirley used Vicodin. Wyman-Gordon notified Shirley that his failure to complete the program constituted grounds for termination but allowed Shirley to reattempt the program. Shirley reentered the program but again left before completing the second step of treatment. Wyman-Gordon fired Shirley for twice failing to complete the treatment program. Shirley filed suit in federal district court, arguing that Wyman-Gordon discriminated against him in violation of the Americans with Disabilities Act (ADA). The district court granted summary judgment for Wyman-Gordon, and Shirley appealed to the Fifth Circuit.

Rule of Law

Issue

Holding and Reasoning (Wiener, J.)

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