Safety-Based Termination After Workplace Firearm and Suicide Threat: ADA and KCRA Analysis in Deryck Huelett v. Louisville Paving Co.

I. Introduction

The Sixth Circuit’s unpublished decision in Deryck Huelett v. Louisville Paving Company, Inc., No. 25‑5241 (6th Cir. Dec. 19, 2025), addresses the intersection of three sensitive areas: workplace safety, firearms, and mental health–related disabilities under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA).

The case arose after a construction worker, who suffered periodic panic attacks, had an emotional episode at a jobsite, voiced suicidal ideation, and picked up a handgun from his vehicle before being disarmed by a coworker. The employer terminated him the next day, citing safety concerns. The employee then alleged disability discrimination—arguing that the real reason for his firing was the company’s perception of his mental health condition.

The Sixth Circuit affirmed summary judgment for the employer. The decision does not break new doctrinal ground so much as it fortifies existing principles: an employer may lawfully terminate an employee—even one with an actual or perceived mental disability—for dangerous workplace conduct involving a firearm, so long as the termination is genuinely based on safety and not on discriminatory animus. The court also reinforces the continued use of the McDonnell Douglas burden‑shifting framework in ADA cases and clarifies what does, and does not, qualify as direct evidence of disability discrimination.

II. Summary of the Opinion

The Sixth Circuit (Judge Larsen, joined by Judges Clay and Kethledge) held that:

There was no direct evidence that Louisville Paving terminated Deryck Huelett because of a disability (actual or perceived).
Even assuming (without deciding) that he could make out a prima facie case of disability discrimination under the ADA (and by extension the KCRA), the employer articulated a legitimate, non-discriminatory reason for termination: serious safety concerns stemming from his handling of a firearm and suicidal statements at a worksite.
Huelett failed to produce sufficient evidence of pretext:
- The company’s explanation did not “shift” over time; it consistently cited the firearm incident and related safety concerns.
- A coworker who intervened to disarm him was not a valid comparator because their conduct was not “substantially identical.”
Any argument that other actions (removal from jobsite, pressure to accept medical care, etc.) were separate “adverse actions” under the Supreme Court’s Muldrow v. City of St. Louis standard was forfeited by being raised only perfunctorily on appeal.
The same analysis disposes of the KCRA claim, which in any event uses an even narrower definition of “disability” than the ADA post‑2008 amendments.

Accordingly, the court affirmed the district court’s grant of summary judgment for Louisville Paving on the disability discrimination claim.

III. Detailed Analysis

A. Factual and Procedural Background

Deryck Huelett worked for Louisville Paving as a construction laborer for roughly seven months. He customarily kept firearms in his car for personal protection. On May 2, 2022, while on a jobsite, he:

Took a lunch break and went to his car.
Argued with his wife by phone about finances and difficulties dealing with his 401(k).
Called the company’s HR specialist, Clay Hoppe, for help with the 401(k). Hoppe perceived Huelett as distressed and breathing heavily and contacted management to have someone check on him.

Coworker Matt Lewis went to Huelett’s car and found him:

“Emotionally distressed,” “hyperventilating,” and crying.
Making statements such as “Maybe it would be better if I was not around” and “Maybe I should just end it.”
Picking up a handgun from inside the vehicle, prompting Lewis to physically restrain his gun hand and order him to drop the weapon. After 30–40 seconds, Huelett complied, and Lewis removed the gun.

A foreman (Blake Cundiff) and the safety specialist (James Bentley) arrived. EMS was called, noted an elevated heart rate and suicidal comments, and urged hospital evaluation. Huelett reluctantly agreed, handed over his keys to Bentley, and later that day the guns were transferred to his wife. Hospital records reflected that he reported a panic attack and admitted saying “something about ‘ending it.’”

The next day, Bentley submitted a safety incident report to Senior VP of HR, Kurt Krug. Krug terminated Huelett’s employment, citing:

His possession and handling of a handgun at the jobsite, and
Concern that he might harm himself or others.

This episode was not his first panic attack at Louisville Paving. Months earlier, he had an attack while operating an excavator. He was sent home and returned the next day, but there was no evidence that he formally disclosed a panic-disorder diagnosis or requested any accommodation.

After his termination, Huelett sued under:

The ADA, alleging disability discrimination; and
The KCRA, which the Kentucky courts interpret through the ADA framework.

The district court granted summary judgment to Louisville Paving on all claims. On appeal, Huelett challenged only the disability discrimination ruling (with some ambiguity about whether his KCRA claim was still pressed; the Sixth Circuit resolved it under the same analysis).

B. Legal Framework

1. Summary Judgment Standard

Citing Franklin American Mortgage Co. v. University National Bank of Lawrence, 910 F.3d 270 (6th Cir. 2018), the panel reiterated that summary judgment is proper if:

There is no genuine dispute of material fact, and
The movant is entitled to judgment as a matter of law (Fed. R. Civ. P. 56(a)).

The appellate court reviews this de novo and views evidence in the light most favorable to the nonmoving party, but it may not rely on “sham” factual disputes created by later affidavits that contradict prior sworn testimony (Lanier v. Bryant, 332 F.3d 999 (6th Cir. 2003)).

2. ADA and KCRA Disability Discrimination

The ADA provides that no covered entity shall discriminate against a qualified individual “on the basis of disability” in the discharge of employees (42 U.S.C. § 12112(a)). Under Lewis v. Humboldt Acquisition Corp., 681 F.3d 312 (6th Cir. 2012) (en banc), the causation standard is “but-for” causation: the plaintiff must show he would not have suffered the adverse action but for his disability.

The KCRA uses similar language and is analyzed under the ADA framework (Brohm v. JH Properties, Inc., 149 F.3d 517 (6th Cir. 1998)), but—as the court notes—Kentucky has retained the pre‑2008, narrower definition of disability (Larison v. Home of the Innocents, 551 S.W.3d 36 (Ky. Ct. App. 2018)). That makes KCRA disability claims generally harder for plaintiffs than ADAAA claims.

3. Direct vs. Indirect Evidence

A plaintiff can prove ADA discrimination via:

Direct evidence: statements or conduct that, without inference, show the employer relied on disability in making its decision (Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008); Bledsoe v. TVA Board of Directors, 42 F.4th 568 (6th Cir. 2022)).
Indirect (circumstantial) evidence: analyzed under the burden‑shifting scheme of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), as reaffirmed for ADA cases in Raytheon Co. v. Hernandez, 540 U.S. 44 (2003) and, in the Sixth Circuit, Hrdlicka v. General Motors, LLC, 63 F.4th 555 (6th Cir. 2023); Edwards v. Shelby County, 159 F.4th 489 (6th Cir. 2025); and Kellar v. Yunion, Inc., 157 F.4th 855 (6th Cir. 2025).

Justice Thomas’s concurrence in Ames v. Ohio Department of Youth Services, 605 U.S. 303 (2025), had questioned the continued soundness of McDonnell Douglas, but the panel correctly recognized that both the Supreme Court and prior Sixth Circuit precedent remain binding (United States v. Elbe, 774 F.3d 885 (6th Cir. 2014)).

4. The McDonnell Douglas Framework in This Case

Under Edwards and Hrdlicka, a prima facie ADA discrimination case requires showing:

The plaintiff is actually disabled or regarded as disabled.
He is otherwise qualified for the position, with or without reasonable accommodation.
He suffered an adverse employment action (here, termination).
The employer knew or had reason to know of his disability.
The position remained open or he was replaced.

Once that is shown, the burden shifts:

The employer must articulate a legitimate, non-discriminatory reason.
The burden then returns to the employee to show this reason is a pretext for discrimination, usually by demonstrating that it:
- Has no basis in fact;
- Did not actually motivate the action; or
- Was insufficient to warrant the action (Hrdlicka, relying on Seeger v. Cincinnati Bell, 681 F.3d 274 (6th Cir. 2012)).

The panel assumes, without deciding, that Huelett could establish a prima facie case and proceeds directly to pretext.

C. Precedents Cited and Their Role in the Court’s Reasoning

1. Direct Evidence Cases

The opinion cites a line of Sixth Circuit cases defining “direct evidence” narrowly:

Bledsoe v. TVA Board of Directors, 42 F.4th 568 (6th Cir. 2022), and Willard v. Huntington Ford, Inc., 952 F.3d 795 (6th Cir. 2020), for the definition that direct evidence “proves the existence of a fact without any inferences.”
Pelcha v. MW Bancorp, Inc., 988 F.3d 318 (6th Cir. 2021), characterizing direct evidence as “smoking gun evidence that explains itself.”
Bent‑Crumbley v. Brennan, 799 F. App’x 342 (6th Cir. 2020), and Coulson v. Goodyear Tire & Rubber Co., 31 F. App’x 851 (6th Cir. 2002), emphasizing that direct evidence usually involves an admission that the employer relied on the protected characteristic.
Treadway v. California Products Corp., 659 F. App’x 201 (6th Cir. 2016), underscoring that the direct‑evidence standard is “high.”

These authorities frame why sympathetic references to “mental health” and “professional help” in internal emails do not suffice as direct evidence that disability motivated the firing decision.

2. Pretext and “Shifting Reasons”

On pretext, the court relies on:

Cicero v. Borg‑Warner Automotive, Inc., 280 F.3d 579 (6th Cir. 2002), for the notion that changing rationales can suggest pretext.
Russell v. University of Toledo, 537 F.3d 596 (6th Cir. 2008), and Ercegovich v. Goodyear Tire & Rubber Co., 154 F.3d 344 (6th Cir. 1998), for comparator analysis: “substantially identical conduct” without differentiating or mitigating circumstances must be shown to establish disparate treatment.
Yarberry v. Gregg Appliances, Inc., 625 F. App’x 729 (6th Cir. 2015), for the rule that an employer may enforce conduct rules even if unwritten, so long as they are job-related and consistent with business necessity.

The court uses these to:

Reject an alleged “shifting reasons” theory by showing the employer’s explanation—safety concerns from the gun incident—was consistent across deposition, discovery responses, and the plaintiff’s own testimony.
Reject the comparator argument by noting that the coworker’s conduct (intervening to disarm) is fundamentally different from the plaintiff’s (suicidal statements while handling a gun).

3. Misconduct vs. Disability

Critically, the court invokes a line of cases holding that employers may discipline or terminate employees for misconduct—even if the misconduct is related to a disability—so long as the action is based on the behavior and not discriminatory animus:

Macy v. Hopkins County School Board of Education, 484 F.3d 357 (6th Cir. 2007) (abrogated on other grounds by Lewis v. Humboldt), approving discipline for conduct in violation of workplace rules even when driven by disability.
Green v. Burton Rubber Processing, Inc., 30 F. App’x 466 (6th Cir. 2002), recognizing threats of violence as a legitimate reason for termination.
Palmer v. Circuit Court of Cook County, 117 F.3d 351 (7th Cir. 1997), cited in Green, for the broader principle that dangerous behavior is not shielded by the ADA.
Lockhart v. Marietta City Schools, 2021 WL 4810172 (6th Cir. Oct. 15, 2021), emphasizing that the ADA’s core question is whether the same conduct would lead to the same discipline if the employee were not disabled.

These authorities lend strong support to the notion that, where an employee brandishes a gun and makes statements about “ending it all,” safety-based termination is presumptively legitimate under the ADA.

4. State Law: Kentucky Gun Statute

The court also notes Kentucky’s firearms statute, Ky. Rev. Stat. § 237.106, which protects certain employee gun rights but allows employers to discipline employees who “handle” firearms in the workplace (other than in self‑defense or similar situations). The district court had relied on this statute to uphold the termination, and the Sixth Circuit saw no ADA conflict: the statute reinforces the legitimacy of disciplining unsafe weapons handling on the job.

5. Procedural Rules on Waiver

As to additional “adverse actions,” the court relies on:

Doe v. Michigan State University, 989 F.3d 418 (6th Cir. 2021), and United States v. Johnson, 440 F.3d 832 (6th Cir. 2006), to hold that arguments “adverted to in a perfunctory manner” and unsupported by developed reasoning are forfeited.

This doctrine is used to avoid addressing whether, in light of the Supreme Court’s Muldrow v. City of St. Louis, 601 U.S. 346 (2024), non-termination actions like removal from a jobsite, pressured medical evaluation, or refusal to pay medical bills qualify as separate adverse actions.

D. The Court’s Legal Reasoning

1. No Direct Evidence of Disability Discrimination

Huelett pointed to a series of post-incident emails among Louisville Paving managers, particularly:

Comments that his situation was “tragic” and “really sad.”
References to “mental health is such a challenge” and “mental health awareness.”
Questions about whether he was “getting help for himself” and a reply that he did not think he needed professional help “for his condition.”

The panel held these did not constitute direct evidence because:

They required inference to connect mental‑health concern to the firing decision.
They did not state that his panic attacks or mental health status were the reason for termination.
At most, they showed empathy and concern—not an admission that the company relied on disability as a basis for firing him.

Under the very stringent standard for direct evidence, the court correctly characterized these internal emails as far from a “smoking gun.” They show awareness and concern about possible mental health problems, but ADA liability demands proof that disability was the but-for cause of the termination, not merely one subject of internal discussion.

2. Legitimate, Non-discriminatory Reason: Safety Concerns from Firearm Incident

At the second stage of McDonnell Douglas, Louisville Paving articulated a straightforward justification:

Huelett’s conduct—picking up a handgun in the car while expressing suicidal thoughts and being physically disarmed by a coworker—presented an immediate safety threat to himself and others on a construction site.
He violated workplace safety norms by handling a gun in this context, and management reasonably perceived a risk that he might “shoot himself or somebody else.”

The fact that this reason is both facially job-related and safety-driven—and corroborated by multiple witnesses and documents—makes it a textbook legitimate, non-discriminatory reason under the ADA.

Notably, the court highlights that even the plaintiff admitted that this was the reason management gave him for the termination. That admission undercuts any suggestion that the firearm explanation was invented after the fact to obscure a discriminatory motive.

3. Pretext: Alleged “Shifting Reasons” Rejected

To show pretext, Huelett argued that Louisville Paving’s explanations had changed—sometimes emphasizing gun possession in violation of a policy, other times describing him as “waving” or “holding” the gun while threatening to “end it all.”

The court reviewed:

His own deposition testimony, where he acknowledged that the company cited both gun presence and fear that he might harm someone.
Louisville Paving’s written discovery responses, which consistently described the incident as brandishing a gun and threatening self-harm on a construction site.
Krug’s deposition, where he repeatedly referenced his understanding that:
- Huelett was holding/waving a gun while saying he was going to “end it all,” and
- That combination of weapon and statement was the basis for termination because it was “threatening and intimidating.”

Although one Krug answer—when read in isolation—might be read to minimize the role of the suicidal statement, the court carefully parses the full transcript and concludes his reasoning was consistent: he viewed the incident as dangerous misconduct (gun + suicidal/homicidal implication), and that is what motivated the firing.

The court also addresses a timing argument about workplace policies addressing guns:

Even if a written gun policy was adopted later or not given to Huelett, that is irrelevant because:
- The stated reason was not “simple possession” in a car but unsafe handling while expressing suicidal thoughts.
- Employers may enforce unwritten safety rules that are job‑related and consistent with business necessity (Yarberry).

Thus, there was no evidence of “shifting reasons” in the sense that the Sixth Circuit has recognized as indicative of pretext.

4. Pretext: Comparator Argument Rejected

Huelett next argued that Louisville Paving applied its Workplace Violence Prevention Policy unevenly:

The policy cautions employees not to place themselves in peril or intercede during an incident.
Lewis arguably violated that directive when he reached into the car and physically restrained Huelett’s gun hand.
Yet Lewis was not disciplined, while Huelett was fired.

Under Russell and Ercegovich, however, a comparator must have engaged in “substantially identical conduct,” and any significant differentiating circumstances defeat the comparison. The panel had little difficulty distinguishing the two:

Huelett’s conduct: creating the peril by handling a firearm while expressing suicidal intent.
Lewis’s conduct: reducing the peril by intervening to disarm a distressed coworker.

Even if both technically violated some aspect of the written policy, those qualitative differences—one posing a danger, the other attempting to avert it—are precisely the kind of “differentiating circumstances” that validate divergent employer responses. Therefore, the comparator argument failed as a way of showing that Louisville Paving’s explanation was insufficient to motivate termination.

5. Pretext: Management Concern About Mental Health

A recurring theme in Huelett’s case was that managers’ references to his “condition” and “mental health” revealed that perceived disability—not safety—drove the termination. The court treated this as an attempt to show that:

The proffered reason (safety) did not actually motivate the decision, and/or
Safety concerns were insufficient in light of mental health‑related comments.

The panel rejected that theory for two reasons:

Perception ≠ causation. The fact that management perceived mental health issues or encouraged professional help does not prove that they fired him because of a (real or perceived) disability. The ADA’s question, per Lockhart, is whether they would have fired him for the same conduct if he had not been disabled or perceived as such.
Misconduct is independently actionable. Under Macy, Green, and Palmer, employers may discipline disabled employees for violating conduct or safety rules, even if the disability caused the misconduct. Here, the conduct—handling a firearm in a threatening context on a construction site—is serious enough that any reasonable employer would deem it terminable, regardless of disability.

Because Huelett offered no evidence that a non-disabled employee who similarly picked up a gun while talking about “ending it all” would have been retained, the safety rationale remains unrebutted.

6. The KCRA Claim

The court treated the KCRA claim as surviving on appeal at most ambiguously, but in any event it:

Applies the same ADA-based analytical framework (Brohm), and
Notes that the KCRA’s narrower, pre‑ADAAA definition of disability makes recovery more difficult for plaintiffs than under the ADA (Larison).

Since the ADA claim fails at the pretext stage, the KCRA claim necessarily fails as well.

7. Adverse Actions and Muldrow: An Issue Not Reached

Huelett, in his reply brief, invoked the Supreme Court’s then-recent decision in Muldrow v. City of St. Louis, which relaxed the adverse-action standard under Title VII. He suggested that, beyond termination, other actions—such as being removed from the jobsite, pressured into medical care, or not having medical bills paid—also qualified as adverse actions meriting review.

The panel declined to engage this argument because:

The district court had only analyzed termination as the adverse action.
Although such a theory was mentioned below, on appeal it was raised only perfunctorily in the reply brief, with no developed legal argument.
Under Doe and Johnson, such undeveloped arguments are not preserved.

Accordingly, the opinion leaves unresolved how Muldrow might apply in the ADA or KCRA context to non-termination actions of the type alleged here.

E. Clarifying Key Legal Concepts

1. Direct vs. Indirect Evidence

Direct evidence in discrimination law is rare. It typically involves statements such as:

“We’re firing you because of your depression.”
“We don’t want people with anxiety disorders on this crew.”

Those require no inference: the statement itself identifies disability as the cause of the decision.

Indirect (circumstantial) evidence is everything else—patterns, timing, comparative treatment, suspicious explanations, etc. The McDonnell Douglas framework is specifically designed for these cases, where you infer intent from surrounding facts rather than explicit admissions.

2. “But-For” Causation Under the ADA

Following Lewis v. Humboldt Acquisition Corp., the ADA requires the plaintiff to show that disability was the but-for cause of the adverse action. In simple terms:

If the employer would have taken the same action even if the employee had no disability (actual or perceived), then disability was not the but-for cause.
There can be multiple contributing factors, but disability must be outcome-determinative.

In this case, the court effectively asks: would Louisville Paving have fired any employee—disabled or not—who handled a gun at a jobsite while saying “I’m going to end it all”? The panel’s answer is clearly yes, based on the record.

3. “Regarded As” Disability

The ADA covers not only those actually disabled but also those “regarded as” having an impairment, even if they are not, in fact, substantially limited in a major life activity. Here, the court does not decide whether Huelett is:

Actually disabled by his panic attacks, or
Regarded as disabled due to management’s concerns about his mental health.

Instead, the court assumes (for argument’s sake) that he could satisfy the “disability” and knowledge elements of his prima facie case and resolves the appeal at the pretext stage. The practical message: even if perceived mental disability is assumed, an employer may still prevail where a clear, non-discriminatory basis for termination exists.

4. Pretext: What Counts?

Under Sixth Circuit law, pretext can be shown in three main ways:

No basis in fact: The alleged reason is factually false (e.g., the employee did not actually handle a gun).
Did not actually motivate: The reason is factually true but was not the real motivation (e.g., the employer seized on a minor policy violation only when a disabled employee committed it).
Insufficient to motivate: Similarly situated employees outside the protected group engaged in comparable conduct but were not fired.

Here:

There was no serious dispute about the facts of the gun incident.
The company’s explanation for the firing was consistent across sources and supported by contemporaneous documentation (safety report, EMS records, witness testimony).
The only purported comparator (Lewis) was not similarly situated because he intervened to reduce the danger rather than cause it.

Thus, none of the classic avenues for proving pretext were available to Huelett on this record.

5. Sham Affidavit Doctrine

The court briefly notes that portions of a late-filed affidavit by Huelett could not be considered to create a triable fact issue if they contradicted his earlier deposition testimony, invoking the “sham affidavit” rule (Lanier v. Bryant).

In practice, this doctrine prevents a party from:

Testifying in one way under oath (e.g., during a deposition), and then
Later submitting an affidavit saying the opposite solely to avoid summary judgment.

This reinforces the importance of accurate, consistent deposition testimony in discrimination cases; plaintiffs cannot salvage weak factual records by later contradicting themselves in affidavits.

6. Kentucky Firearm Law and Workplace Discipline

Kentucky law (Ky. Rev. Stat. § 237.106) generally protects an employee’s right to keep a firearm in a locked vehicle in employer parking areas. But it also:

Allows employers to take disciplinary action when an employee handles a firearm on the premises (absent self‑defense, defense of another, or defense of property).

The Sixth Circuit’s use of this statute underscores a key point for both ADA and state-law practice: a statutory scheme that protects some aspects of gun possession does not immunize an employee from discipline for dangerous or threatening gun-related conduct.

F. Impact and Practical Implications

1. For Employers

The decision reinforces several practical points for employers, particularly in safety-sensitive industries:

Safety-based discipline remains paramount. Employers may—and should—act decisively when employees engage in conduct that reasonably appears to threaten themselves or others, even when mental health issues are involved.
Document the conduct, not the diagnosis. The employer’s success here was rooted in:
- A detailed safety incident report,
- Consistent descriptions of the conduct in internal and litigation documents, and
- Clear testimony about the decision-maker’s understanding at the time.
Compassion is not evidence of discrimination. Managers can (and should) express concern for employees’ mental health and encourage professional help. Such comments, standing alone, do not convert a safety-based decision into disability discrimination.
Written policies help but are not dispositive. While firearms and workplace-violence policies are advisable, the court confirms that unwritten but job-related safety rules can also support discipline (Yarberry).
Comparator discipline must be consistent. The decision illustrates how important it is to distinguish the nature and severity of different employees’ conduct when imposing discipline, and to articulate those distinctions clearly if litigation arises.

2. For Employees and Plaintiffs

From an employee/plaintiff perspective, the case underscores:

Misconduct is not shielded by the ADA. Even if panic attacks or other mental health conditions lead to behavior that violates safety rules, the ADA does not prevent employers from responding to serious threats.
Proof of disability is not enough; causation is crucial. Plaintiffs must connect disability to the adverse action as a but-for cause. Merely showing that the employer knew about or discussed mental health concerns is not sufficient.
Comparators must be truly similar. Effective comparator evidence requires showing that non-disabled employees engaged in nearly identical conduct under similar circumstances but were treated more leniently.
Be careful with appellate briefing. Novel arguments about what constitutes an “adverse action,” especially after cases like Muldrow, must be developed thoroughly in the opening brief. Raising them only in a reply or without analysis risks forfeiture.
Consistency in testimony matters. Contradicting prior deposition testimony via later affidavits will likely be disregarded under the sham-affidavit doctrine, making it essential to present a coherent factual account from the outset.

3. For ADA and KCRA Jurisprudence

Although “not recommended for publication,” this opinion contributes to the Sixth Circuit’s ADA/KCRA jurisprudence by:

Reaffirming the continued vitality of the McDonnell Douglas framework in ADA cases, notwithstanding academic and judicial criticism.
Strengthening the line of cases holding that dangerous conduct, including threats of violence or self-harm, can be a legitimate basis for termination even when disability is implicated.
Clarifying that expressions of mental-health concern by management will not, by themselves, convert a safety-justified termination into unlawful discrimination.
Demonstrating how the ADA interacts with state gun statutes: ADA claims will generally not override a state law that permits employers to discipline unsafe firearms handling on their premises.

Future litigants may cite this case (as persuasive authority) in arguing that:

Firearm-related incidents in the workplace are among the clearest examples of legitimate, non-pretextual reasons for termination, especially when combined with suicidal or homicidal statements.
ADA plaintiffs must offer more than sympathetic or mental-health-oriented language in emails to carry their burden at the pretext stage.

IV. Conclusion

Huelett v. Louisville Paving Co. underscores a core principle of disability discrimination law: the ADA and KCRA protect employees from being fired because of disability, not from being disciplined for serious misconduct that endangers themselves or others, even when such conduct is rooted in mental health issues.

The Sixth Circuit’s analysis carefully distinguishes:

Genuine safety concerns about a worker handling a firearm while expressing suicidal thoughts, from
Unlawful reliance on stereotypes or animus about mental illness.

By holding that the employer’s safety-based rationale was consistent, well-documented, and unrebutted by meaningful evidence of pretext, the court reaffirms that workplace safety—and especially control of firearms on hazardous jobsites—can justify termination under the ADA, provided that the employer would treat similarly dangerous conduct the same way regardless of disability. At the same time, the opinion implicitly encourages employers to respond to mental health crises with both compassion and adherence to safety protocols, and it reminds plaintiffs that successful disability discrimination claims demand a robust showing of causation and pretext, not merely evidence that mental health was part of the conversation.