Job-Related Medical Documentation Requirements Consistent with Business Necessity Under the ADA

Introduction

This commentary examines the Third Circuit’s unpublished decision in James Chadwick v. Norfolk Southern Railway Co., No. 24-1520 (3d Cir. Apr. 18, 2025). James Chadwick, a locomotive engineer who developed a seizure disorder, sued his employer, Norfolk Southern Railway (“Norfolk”), under the Americans with Disabilities Act (“ADA”), the Rehabilitation Act (“RA”), and the Pennsylvania Human Relations Act (“PHRA”). He alleged that Norfolk discriminated against him by placing him on involuntary medical hold in 2020 and thereby suspending his service, rather than because he failed to provide updated medical documentation necessary for his Federal Railroad Administration (“FRA”) recertification.

Key issues:

Whether Norfolk’s request for up-to-date medical information about Chadwick’s seizure disorder was “job‐related and consistent with business necessity” under 42 U.S.C. §§ 12112(b)(6) and (d)(4)(A);
Whether the suspension pending receipt of that information constituted an adverse employment action “as a result of discrimination”; and
Whether, in evaluating Chadwick’s prima facie case, the court properly considered backward-looking expert testimony on his qualifications and correctly characterized a medical hold as non-adverse.

Summary of the Judgment

The Third Circuit affirmed the district court’s grant of summary judgment to Norfolk. It held that:

Chadwick failed to prove his suspension was “as a result of discrimination,” since Norfolk had a valid, job‐related, business-necessary reason—i.e., obtaining safety-related medical updates under FRA‐authorized recertification standards.
Although the district court made two technical errors—(1) in suggesting it could not consider backward-looking expert evidence to assess Chadwick’s 2020 qualifications and (2) in deeming a medical suspension non-adverse—the correct disposition remains because Chadwick lacked any discriminatory motive by Norfolk.

The court therefore concluded that Norfolk’s medical hold pending updated neurologist reports did not violate the ADA, RA, or PHRA.

Analysis

Precedents Cited

Tice v. Centre Area Transportation Authority, 247 F.3d 506 (3d Cir. 2001): Affirmed that employer‐ordered medical inquiries are permissible if they are job‐related and consistent with business necessity.
McNemar v. Disney Store, Inc., 91 F.3d 610 (3d Cir. 1996): Authorized consideration of after-acquired or backward-looking evidence when assessing whether an individual was “otherwise qualified” at a past date.
Fowler v. AT&T, Inc., 19 F.4th 292 (3d Cir. 2021): Defined the scope of “adverse employment action” to include any material change in employment terms, conditions, or privileges.
Simpson v. Kay Jewelers, 142 F.3d 639 (3d Cir. 1998): Held that an employer’s failure to raise one explanation before the EEOC does not, on its own, prove discriminatory motive.

Legal Reasoning

The Third Circuit applied the familiar three-element prima facie test for disability discrimination under the ADA, RA, and PHRA:

The plaintiff has a disability;
The plaintiff is otherwise qualified to perform the essential functions of the job, with or without reasonable accommodation; and
The plaintiff suffered an adverse employment action “as a result of discrimination.”

Here, Norfolk’s recertification requirement derived from FRA regulations (49 C.F.R. § 240.217(c)) and its own FRA-authorized policies (49 C.F.R. § 240.1(b)). Because locomotive engineers occupy a safety-sensitive role, Norfolk legitimately sought current medical details—last seizure date, side effects, and risk of recurrence—to ensure safe operation. Under 42 U.S.C. §§ 12112(b)(6) and (d)(4)(A), such medical inquiries and standards are lawful when they are “job‐related and consistent with business necessity.” Norfolk’s suspension of Chadwick was a neutral, remedial measure pending compliance—not an orchestrated effort to discriminate against him for his disability.

Although the district court initially questioned its ability to assess Chadwick’s 2020 qualifications without contemporaneous medical evidence, the Third Circuit clarified that backward-looking expert testimony (per McNemar) could inform whether he remained qualified when placed on hold. Similarly, the court noted that an involuntary suspension affects pay, seniority, and benefits, and thus is an adverse employment action under Fowler. Nevertheless, because there was no evidence of discriminatory intent, summary judgment for Norfolk was appropriate.

Impact

This decision reinforces employers’ ability to impose medically based recertification requirements for safety-sensitive roles, so long as those requirements adhere to the ADA’s “business necessity” standard. It clarifies that:

Employers may insist on up-to-date medical information before permitting an employee to resume safety-critical duties;
Lapses or delays in providing such information justify temporary suspension without giving rise to an inference of disability discrimination;
Courts evaluating ADA claims may consider backward-looking evidence when determining past qualifications; and
An involuntary medical hold can qualify as an adverse employment action, but absence of discriminatory motive is dispositive.

Future litigants and lower courts will look to this ruling when balancing employee rights under the ADA against legitimate workplace safety and regulatory compliance concerns.

Complex Concepts Simplified

Job-Related and Consistent with Business Necessity: Under the ADA, an employer can require a medical exam or inquiry if it relates directly to the job’s essential functions and is necessary for safe, efficient operation.
Backward-Looking Evidence: Courts may use expert testimony about past conditions (even if obtained after the fact) to determine whether an employee met qualification standards at an earlier time.
Adverse Employment Action: Any significant change in employment status, pay, benefits, or privileges. A temporary medical suspension that reduces pay and seniority qualifies, even if no long-term termination occurs.

Conclusion

Chadwick v. Norfolk Southern Railway Co. underscores that safety-related medical inquiries and documentation requirements, when grounded in regulatory authority and business necessity, do not constitute disability discrimination—even if an employee is temporarily suspended for non-compliance. The ruling affirms employers’ discretion to enforce recertification processes in safety-sensitive contexts and provides clarity on evidentiary standards for assessing qualifications and adverse actions. This decision will guide both courts and employers in resolving ADA disputes that involve procedural medical holds and compliance with federal safety regulations.