No ADA Discrimination Absent But-For Causation: Hoffstead v. Metra

Introduction

Hoffstead v. Northeast Illinois Regional Commuter Railroad Corp. (“Metra”) arose after a Metra canine handler, Timothy Hoffstead, tested positive for amphetamines and opioids in a random drug test. The medical review officer (“MRO”) initially reported the result as positive because Hoffstead did not respond in time with proof of his prescription medications. Metra suspended Hoffstead, required him to enter a mandatory rehabilitation and education program under its collective bargaining agreement, removed him from his canine duties, and did not consider him for a subsequent canine‐handler vacancy. Once Hoffstead provided proof of valid prescriptions, the MRO reversed the test result to “negative,” but Metra nevertheless enforced its internal discipline. Hoffstead sued under the Americans with Disabilities Act (ADA), claiming Metra’s actions were motivated by his disabilities (attention deficit disorder, migraines, and a wrist injury). The Seventh Circuit affirmed summary judgment for Metra, holding that Hoffstead could not show his disability was the “but-for” cause of any adverse action.

Summary of the Judgment

The Seventh Circuit applied the well-settled ADA framework: a plaintiff must show (1) a disability; (2) qualification for the job with or without reasonable accommodation; and (3) an adverse employment action “because of” the disability (the “but-for” causation standard). The court agreed that Hoffstead has disabilities and was qualified for his job, but held he failed to create a genuine issue of material fact on causation. Every adverse action followed Hoffstead’s own failure to timely explain his positive result and his voluntary waiver of a disciplinary hearing in favor of the rehabilitation program. Metra’s subsequent decisions—including continuing the program after the test reversal, removing Hoffstead’s canine assignment, refusing to consider him for the open handler position (due to a good‐faith but mistaken belief that he had been decertified), and rejecting his seniority bid—were tied to enforceable rules and honest mistakes, not discriminatory animus. Finally, the court rejected Metra’s contention that the Railway Labor Act (RLA) precluded adjudication of Hoffstead’s seniority claim, concluding that ADA rights exist independent of collective bargaining agreements.

Analysis

Precedents Cited

Monroe v. Ind. Dep't of Transp., 871 F.3d 495 (7th Cir. 2017) – Reaffirmed ADA’s “but-for” causation requirement for discrimination claims.
Serwatka v. Rockwell Automation, Inc., 591 F.3d 957 (7th Cir. 2010) – Established ADA summary-judgment standards.
Ortiz v. Werner Enters., Inc., 834 F.3d 760 (7th Cir. 2016) – Directed courts to view all evidence in the aggregate, not piecemeal, when evaluating summary judgment.
Green v. Nat’l Steel Corp., 197 F.3d 894 (7th Cir. 1999) – Confirmed an employer’s right to make business decisions, even inefficient ones, absent discriminatory intent.
Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246 (1994) – Defined RLA’s “minor dispute” doctrine and arbitration requirement.
Brown v. Ill. Central R.R. Co., 254 F.3d 654 (7th Cir. 2001) – Clarified RLA preemption does not bar claims based on rights independent of a collective bargaining agreement.
Carlson v. CSX Transportation, Inc., 758 F.3d 819 (7th Cir. 2014) – Held Title VII claims survive even if a CBA might justify the employer’s decision.

Legal Reasoning

1. ADA “But-For” Causation
The court reiterated that an ADA plaintiff must prove an adverse employment action occurred “because of” the disability. Merely showing a correlation between disability and discipline is insufficient; the disability must be the decisive cause. Here, Hoffstead’s removal and mandated rehabilitation derived directly from his failure to respond to the MRO and his voluntary waiver of the disciplinary hearing. Metra’s enforcement of its drug policy—even after the test reversal—was consistent with a facially neutral rule tied to Hoffstead’s own choices, not his disability.

2. Good-Faith Misperceptions Are Non-Discriminatory
Chief Perez’s mistaken belief that Hoffstead had been decertified justified Metra’s refusal to consider him for the vacant canine handler position. Under Seventh Circuit law, an honest but incorrect rationale is not pretextual unless the plaintiff shows the employer lied or lacked any honest basis. Hoffstead produced no evidence that Perez’s belief was dishonest.

3. Railway Labor Act Preemption
Metra argued that the RLA barred judicial review of Hoffstead’s claim that Metra applied the seniority provisions of the collective bargaining agreement discriminatorily. The court explained that rights arising under federal statutes, like the ADA, survive even where a CBA might also bear on the claim. Citing Carlson and Brown, the court held that Hoffstead’s ADA-based challenge does not require interpreting or rewriting the CBA; it simply asks whether Metra’s actions were motivated by disability discrimination, a question independent of the CBA’s terms.

Impact

Reaffirms the strict “but-for” causation standard in ADA claims, limiting relief where employer actions flow from employee choices or misunderstandings rather than discriminatory animus.
Confirms that employers may enforce neutral drug and rehabilitation policies—even if applied after test reversals—so long as the rules are uniformly administered and the employer honestly believes they apply.
Clarifies that honest mistakes by supervisors (e.g., beliefs about decertification) will not be second-guessed as pretext absent evidence of intentional discrimination.
Limits RLA preemption in hybrid claims involving statutory rights (ADA) and collective bargaining rights, ensuring employees can seek statutory relief without forcing arbitration of independent statutory causes of action.

Complex Concepts Simplified

“But-For” Causation: The employee’s disability must be the decisive factor in the employer’s adverse action. If another factor—like the employee’s own choice—accounts for the decision, there is no ADA violation.
Summary Judgment: A procedure to end a case before trial if no genuine factual dispute exists. Courts view all evidence in the light most favorable to the non-moving party.
Medical Review Officer (MRO): A neutral medical professional who reviews drug-test results, contacts the employee for explanation, and certifies whether positives arise from legitimate prescriptions.
Railway Labor Act “Minor Disputes”: Conflicts requiring interpretation of a collective bargaining agreement must be arbitrated rather than litigated. But if a statutory right (e.g., under the ADA) is asserted independently, courts retain jurisdiction.

Conclusion

Hoffstead v. Metra underscores that ADA discrimination claims demand proof the disability was the but-for cause of adverse employment actions. Employers may rely on neutral policies and honest misperceptions without running afoul of the ADA, so long as protected status is not the driving force. The decision also draws clear lines between collectively bargained employment provisions and independent statutory rights, preserving employees’ access to judicial relief under the ADA even when a CBA addresses similar matters. As a result, the Seventh Circuit has fortified both the integrity of employment‐discipline procedures and the precise contours of ADA protection.