ST. LOUIS, MISSOURI — A federal appeals court has ruled that a commercial truck driver’s heart condition does not qualify as a disability under the Americans with Disabilities Act, affirming dismissal of his discrimination and retaliation lawsuit against his former employer.

In Stephens v. U.S. Environmental Services LLC, the 8th U.S. Circuit Court of Appeals held that the driver’s atrial fibrillation did not substantially limit a major life activity and therefore did not meet the ADA’s legal definition of a disability.

The driver claimed his heart condition limited his breathing and cardiovascular function and that he refused to perform certain work that could aggravate his symptoms. During a medical evaluation requested by the company, a nurse placed his commercial driver’s license on hold after an electrocardiogram showed “abnormal” results.

However, both the nurse and the driver’s cardiologist ultimately determined he was medically and physically fit to perform his job. The cardiologist later reviewed the EKG and found it to be normal for the driver. A supervised stress test also returned “unremarkable” results, and the cardiologist cleared him to resume commercial driving duties, noting he was “doing very well.”

While his CDL was temporarily on hold, the driver asked to perform other work. The employer denied the request, and the driver resigned, stating he did not feel comfortable continuing in his role. He later filed suit alleging disability discrimination, retaliation, and failure to accommodate.

The district court granted summary judgment to the employer, and the 8th Circuit affirmed, finding that the medical evidence did not show the driver’s condition substantially limited a major life activity as required under the ADA.

The appeals court also rejected his failure-to-accommodate claim. The driver argued he requested a respirator before cleaning underground tanks, work that fell outside his normal driving duties. The court determined the respirator request was for general safety equipment available to all employees and not clearly tied to a disability-related accommodation request.

The ruling serves as an important reminder for trucking companies and CDL holders that, even under the ADA’s broad standards, a medical condition must substantially limit a major life activity to qualify as a protected disability. The decision also highlights the role of medical evaluations and fitness-for-duty determinations in cases involving commercial drivers.

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