## Facts

- The City of Dallas adopted a Driver Safety Program requiring medical qualifications for employees whose jobs made driving on public roads an intrinsic duty; those jobs were designated “Primary Driver” positions.
- The program’s key standards (modeled on federal transportation safety regulations) disqualified: (1) insulin-dependent diabetics, and (2) employees lacking 20/40 corrected vision and a specified horizontal field of vision in each eye.
- Lyle Chandler, a city employee in a Primary Driver classification, had insulin-dependent diabetes and failed the city’s driver physical; the City initially retained him but required another employee to drive him to work sites.
- Chandler experienced multiple hypoglycemic episodes at work, including incidents requiring emergency treatment, and was involved in other workplace safety problems.
- Adolphus Maddox held a Primary Driver classification but failed the driver physical because impaired vision in his left eye could not be corrected to meet the program’s standards.
- After disputes and reclassifications, Chandler and Maddox were placed in non-Primary Driver positions.
- They sued on behalf of themselves and a putative class, alleging the medical standards violated § 504 of the Rehabilitation Act and the Fourteenth Amendment (via 42 U.S.C. § 1983).
- The district court ruled for the plaintiffs and certified a class; the City appealed.

## Issues

1. Whether Chandler and Maddox were “handicapped” under the Rehabilitation Act, including whether they were “regarded as” handicapped by the City.
2. Whether they were “otherwise qualified” to perform the essential functions of Primary Driver positions, with or without reasonable accommodation.
3. Whether the City’s program violated the Rehabilitation Act or the Fourteenth Amendment (Equal Protection or Due Process) actionable under § 1983.
4. Whether class certification was proper given the nature of the disability and qualification inquiries.

## Decision

- The Fifth Circuit reversed the district court’s judgment for Chandler and Maddox.
- The court held the plaintiffs did not establish Rehabilitation Act liability because they failed to show they were both covered as handicapped and otherwise qualified for Primary Driver work.
- The court rejected the argument that the City “regarded” them as broadly disabled where the City retained them in other positions rather than treating them as generally unemployable.
- The court concluded the plaintiffs had not shown reasonable accommodations that would allow them to perform the core function—safe driving—without negating the job’s essential requirements.
- The court rejected the § 1983 constitutional claims, finding the safety-based standards rationally related to legitimate governmental objectives and not an arbitrary deprivation.
- The court held class certification was improper because disability status and job qualification depended on individualized medical and job-function determinations.

## Legal Principles

- A medical condition does not qualify as a Rehabilitation Act handicap absent proof that it substantially limits a major life activity, or that the employer regarded the employee as so limited in a broad, employment-restricting sense.
- Disqualification from a narrow category of safety-sensitive work, without more, is generally insufficient to show the individual is “regarded as” handicapped.
- In safety-sensitive positions, an employer may define essential job functions to include meeting objective medical standards tied to safe performance, including standards drawn from longstanding federal safety regulations.
- A plaintiff must show an accommodation that permits performance of the essential functions; an arrangement that removes the essential function (e.g., having others perform the required driving) is not a required accommodation.
- Class treatment is generally inappropriate where liability depends on individualized assessments of impairment, its functional impact, specific job duties, safety risk, and available accommodations.
- Equal protection challenges to disability-based job standards are evaluated under rational-basis review when no suspect classification or fundamental right is implicated; safety-based criteria ordinarily satisfy that standard.

## Conclusion

The Fifth Circuit reversed the plaintiffs’ Rehabilitation Act and § 1983 victories and set aside class certification, holding that the City’s safety-based driver medical standards were permissible and that disability coverage, qualification, and accommodation required individualized proof not suited to classwide resolution.


Chandler v. City of Dallas, 2 F.3d 1385 (5th Cir. 1993)