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 and conduct. Dr. Carney refused the coaching, viewing it as an unlawful medical examination, and was subsequently notified that his appointment would not be renewed. He sued Emory, alleging a violation of the Americans with Disabilities Act, but the district court granted summary judgment in favor of the university.
The court’s reasoning
The Eleventh Circuit reviewed the district court’s grant of summary judgment de novo. The court analyzed whether the coaching requirement amounted to a prohibited medical examination under Section twelve thousand one hundred twelve, subsection (d)(4)(A) of Title forty-two of the United States Code. The court noted that while the Equal Employment Opportunity Commission guidance defines a medical examination as a procedure seeking information about physical or mental impairments, the coaching here was focused on navigating conflict, leadership, and communication skills. The court found that Dr. Carney’s post-termination questions about sleep and stress were not sufficient to prove the coaching was designed to reveal a mental disorder. Furthermore, the court deemed it speculative to infer that an alternative coach would have administered a medical test based on a single statement by Dr. Carney’s supervisor.
What it means going forward
Employers may require non-clinical leadership coaching and check-ins regarding well-being following significant life events without triggering ADA medical examination prohibitions, provided the inquiry is not designed to reveal a disability.
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