Jarvela v. Crete Carrier Corp., No. 13-11601 (11th Cir. 2014)Annotate this Case
Plaintiff filed suit against his employer, alleging that the employer violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, by terminating him based on his diagnoses of alcoholism. The court agreed with the employer that plaintiff was not qualified under DOT regulations to drive a commercial truck because he had a current clinical diagnosis of alcoholism. Because the court determined that plaintiff was not entitled to drive a commercial truck under the DOT regulations, the court need not address whether the employer's company policy also supported that determination. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer on the ADA claim. In regards to the FMLA claims, the court agreed with the district court's determination that plaintiff's interference claim failed because the employer would have discharged plaintiff regardless of his FMLA leave, and plaintiff's retaliation claim failed because he could not show that the employer's decision to terminate him was causally related to his FMLA leave. Accordingly, the court affirmed the district court's grant of summary judgment as to the FMLA claims.