Background
Dr. K. Jeff Carney, a urologist at Emory University, was ordered to undergo leadership coaching after an internal investigation into complaints from medical residents regarding his professionalism. Dr. Carney refused the coaching, viewing it as an unlawful medical examination, and was subsequently not renewed in his position. He sued Emory, alleging a violation of the Americans with Disabilities Act.
The court’s reasoning
The court reviewed the record to determine if the coaching requirement amounted to a medical examination under the ADA. The court found that the coaching was specifically for navigating conflict and leadership, not for diagnosing mental impairments. Although the coach asked questions about sleep and stress, these were general well-being inquiries following a significant life event like job loss. The court concluded that the record did not support a reasonable inference that the coaching involved a procedure designed to reveal a disability.
What it means going forward
Employers may require non-clinical leadership coaching for professional development without triggering ADA medical examination protections, provided the coaching does not involve diagnostic testing or inquiries designed to reveal a disability.
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