A federal appeals court ruled that Union Pacific Railroad did not violate the Americans with Disabilities Act when it barred a conductor from operating trains after he recovered from a stroke. The court determined the company’s decision was reasonable under safety regulations.
Workplace restrictions after stroke recovery
The conductor suffered an ischemic stroke at home while off duty. His neurologist cleared him to return to work, but Union Pacific’s chief medical officer imposed a one-year restriction on driving trains. The decision cited medical records indicating a heightened risk of seizures.
When the year ended, a Union Pacific physician reviewed updated medical evidence and Federal Motor Carrier Safety Administration guidelines. The physician extended the restriction to five years, concluding the conductor’s condition still posed a safety risk. The conductor never returned to work and later filed a lawsuit against the railroad for ADA violations.
Court upholds Union Pacific’s assessment
The 8th U.S. Circuit Court of Appeals upheld a lower court’s summary judgment in favor of Union Pacific. The court agreed the company had shown the conductor’s stroke and subsequent brain hemorrhage created a heightened risk of seizures. While the risk might have been low, the potential harm—such as a seizure while operating a train—was severe.
Under the ADA, employers can restrict employees with disabilities if they prove the disability poses a significant risk to others that cannot be reduced by reasonable accommodations. Union Pacific met this requirement through multiple fitness-for-duty evaluations, medical record reviews, and consultations with FMCSA guidelines.
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The conductor’s attorneys did not respond to requests for comment.
The ruling follows a 2022 decision by the 3rd Circuit, which upheld Norfolk Southern Railway’s restriction of a locomotive engineer with a heart condition that risked loss of consciousness. Both cases rely on the ADA’s “direct threat” provision, allowing employers to prioritize safety in roles where impairment could endanger others—even when an employee’s physician disagrees.
The 8th Circuit acknowledged a reasonable jury might have sided with the conductor’s treating physician, who believed he could safely return. Still, the court found no proof Union Pacific’s assessment was flawed.
Such decisions show courts often side with employers in safety-sensitive industries, especially when medical guidelines and internal reviews support their conclusions. Workers in transportation, energy, or healthcare fields may face steep challenges when contesting disability-related restrictions, even after full recovery.
Union Pacific’s policy required the conductor to remain on leave until the five-year restriction ended.
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