Railroad Company Was Correct in Requesting Medical Records from Locomotive Engineer, Appeals Court Rules

Case Name: Michael Coffey, Jr. v. Norfolk Southern Railway Co.

Court:  United States District Court – Fourth Circuit

Date of Opinion: January 14th, 2022

Judges: Wilkinson, Motz, & Harries

Overview:  Locomotive engineer appealed a decision of the district court granting summary judgment in favor of the employer regarding a request for medical records.

Background: Michael Coffey, Jr. was employed as a locomotive engineer for Norfolk Southern Railway Company from 1999 to 2017.  In 2012, a train that Coffey was conducting derailed and a drug test showed that there was the presence of amphetamines in his system.  After another drug test four years later, amphetamines and codeine were found in Coffey’s system.  Coffey explained that he was taking these medications for ADHD and for a back condition.

Norfolk Southern then requested that Coffey submit medical records which should address Coffey’s diagnosis, symptoms, as well as other information.  Coffey states that he asked his doctors to send his medical records to Norfolk Southern, but the company says that they never received them.

After receiving some medical records from his doctors, Norfolk Southern declared that the information in the records were not satisfactory.  After a disciplinary hearing the company stated that the records sent to them beforehand (over 400 pages) still was not satisfied with the content of the records and subsequently terminated Coffey’s employment.

Coffey then filed a complaint in federal district court alleging that Norfolk Southern violated the Americans With Disabilities Act by discriminating against his because of his disability as well as making improper medical requests and then terminating him. 

The district court granted summary judgment in favor of the defendant and Coffey filed an appeal, attempting to reverse the district court’s opinion that the medical requests were proper under the ADA.

The appeals court opined that Norfolk Southern’s request for medical information was satisfactory under the federal statutes to make sure that Coffey was able to operate a train in a safe manner.  The court states that Norfolk Southern’s requests for medical information were job-related and “consistent with a business necessity. 

Conclusion:  The appeals court affirmed the opinion of the district court, granting summary judgment in favor of the defendant.

Steven M. Cohen
Law Librarian | + posts

Steven M. Cohen is a law librarian at a midsize law firm in New York City.  He was the creator of Library Stuff, one of the first library blogs, which lasted over 15 years.  He obtained his MLS from Queens College in 2002.  His passions include legal research, reading novels, and rooting on his favorite sports teams.