## Facts

- Franklin Owusu-Ansah worked for The Coca-Cola Company, receiving multiple promotions before the events at issue.
- In December 2007, during a meeting with his manager, he complained of national-origin discrimination by managers and coworkers.
- During the meeting, he became agitated, banged his hand on the table, and said someone was “going to pay,” which management interpreted as a potential threat to employees.
- Coca-Cola consulted an independent psychologist specializing in threat assessment, who evaluated Owusu-Ansah, found him stressed and agitated (possibly delusional), and recommended paid leave and further evaluation.
- Coca-Cola placed him on paid leave and later required a psychiatric/psychological fitness-for-duty evaluation to determine whether any mental condition could impair safe and successful performance of job duties.
- Owusu-Ansah initially resisted aspects of evaluation and information-sharing; Coca-Cola advised he would be terminated if he refused the required evaluation.
- A psychiatrist later recommended a personality test before clearing him; after Owusu-Ansah completed it and scored within normal limits, Coca-Cola returned him to work.

## Issues

1. Whether requiring a psychiatric/psychological fitness-for-duty evaluation violated ADA § 12112(d)(4)(A), which bars employee medical examinations unless job-related and consistent with business necessity.
2. Whether Coca-Cola had an objective, reasonable basis—grounded in specific conduct and reliable information—to question Owusu-Ansah’s ability to perform his job safely.
3. Whether the scope of the examination and interim employment actions were appropriately limited to the employer’s stated safety and performance concerns.

## Decision

- The Eleventh Circuit affirmed summary judgment for Coca-Cola.
- The court held the fitness-for-duty evaluation was job-related and consistent with business necessity under ADA § 12112(d)(4)(A).
- The court found Coca-Cola relied on specific observed behavior, workplace safety concerns, and an independent professional recommendation rather than stereotypes or unsupported fears.
- The court concluded the examination process was targeted to assessing safe performance and was not broader than necessary.
- Because Owusu-Ansah did not object to the magistrate judge’s factual recitation adopted by the district court, appellate review of those facts was limited to plain error or manifest injustice.

## Legal Principles

- ADA § 12112(d)(4)(A) permits an employer-required medical examination of a current employee only if it is job-related and consistent with business necessity.
- An employer satisfies the business-necessity standard when it has a reasonable, objective basis, based on specific conduct and reliable information, to doubt an employee’s ability to perform essential job functions or to believe the employee may pose a safety risk.
- Use of independent professional assessment can support the objective basis for requiring a fitness-for-duty evaluation.
- The examination and related measures should be limited to determining fitness to perform duties safely and successfully and should not exceed what is necessary to address the identified concern.
- Summary judgment is appropriate when the evidence, viewed in the nonmovant’s favor, presents no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.

## Conclusion

The court held that an employer does not violate the ADA by requiring a psychological fitness-for-duty evaluation when an employee’s specific workplace conduct reasonably raises safety and performance concerns and the employer responds with a professionally supported, narrowly focused examination process consistent with business necessity.


Owusu-Ansah v. Coca-Cola Co., 715 F.3d 1306 (11th Cir. 2013)