Owusu-Ansah v. Coca-Cola Co.
United States Court of Appeals for the Eleventh Circuit
715 F.3d 1306 (2013)
An employer does not violate the Americans with Disabilities Act by requiring an employee to participate in a medical examination that is job-related and consistent with business necessity.
Beginning in 1999, Franklin Owusu-Ansah (plaintiff) worked for Coca-Cola Co. (defendant) at a call center. In December 2007, Owusu-Ansah told his manager that several coworkers had discriminated against him and harassed him because he was from Ghana. According to Owusu-Ansah's manager, Owusu-Ansah banged his fist on the table, raised his voice, and said someone would "pay for this." Owusu-Ansah later declined to speak with Coca-Cola's senior human-resources manager about his concerns. However, Owusu-Ansah agreed to speak with Dr. Marcus McElhaney, an independent consulting psychologist specializing in crisis management and threat assessment. McElhaney believed that there was a strong possibility that Owusu-Ansah was delusional and recommended a fitness-for-duty evaluation. Coca-Cola placed Owusu-Ansah on paid leave and required him to undergo a fitness-for-duty evaluation with psychiatrist Dr. Christopher Riddell. Owusu-Ansah met with Riddell but initially refused to discuss his employment issues. After Coca-Cola warned Owusu-Ansah that he would be terminated unless he cooperated, Owusu-Ansah completed the evaluation. Dr. Riddell cleared Owusu-Ansah to return to work in April 2008. Owusu-Ansah then sued Coca-Cola, arguing that Coca-Cola had violated the Americans with Disabilities Act (ADA) by compelling Owusu-Ansah to complete the evaluation. The district court granted Coca-Cola's motion for summary judgment, holding that the evaluation did not violate the ADA. Owusu-Ansah appealed.
Does an employer violate the Americans with Disabilities Act by requiring an employee to participate in a medical examination that is job-related and consistent with business necessity?