If you are an employee living with a heart condition, chronic illness, or any serious diagnosis, you probably assume your employer cannot fire you because of it. You assume disability discrimination laws, including Americans with Disabilities Act (“ADA”), protects you. But not every medical condition qualifies as a disability under the ADA, and misunderstanding that can turn what feels like wrongful termination into a dismissed case.
That is what happened in Donald Stephens v. United States Environmental Services LLC, 2026 WL 393724. Stephens worked as an Operator for his employer in a position requiring a commercial driver’s license. During a shift cleaning underground tanks, he raised safety concerns, requested equipment, and disclosed that he had a heart condition. His employer required a medical exam. A nurse placed a 45-day hold on his CDL. Stephens asked to perform non-driving work. The employer refused. He resigned and brought claims for disability discrimination and retaliation.
The United States Court of Appeals for the Eighth Circuit affirmed summary judgment for the employer. The Court held that Stephens failed to show his condition “substantially limits” a major life activity. The Court also held that his respirator request was not protected activity under ADA retaliation law.
For any employee who feels wrongfully fired or pushed out because of a medical condition, this case shows how technical employment law can become — and why having the best employment lawyer matters from the beginning.
What Qualifies As A Disability Under The ADA?
In everyday conversation, disability means medical condition. In employment law, disability has a specific definition.
Under 42 U.S.C. § 12102(1), a disability means:
(A) a physical or mental impairment that substantially limits one or more major life activities;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment.
Those are three separate paths for an employee claiming disability discrimination.
Most disability discrimination cases focus only on the first path — actual substantial limitation. That is the route Stephens relied on. The second path protects an employee with a documented history of a substantially limiting impairment. The third path protects an employee who is treated by an employer as if he has such an impairment.
The Eighth Circuit Court of Appeals noted that Stephens did not challenge the district court’s finding that the employer did not regard him as disabled and therefore “has abandoned his ‘regarded as disabled’ claim on appeal.”
The ADA gives employees three legal doors. In this disability discrimination case, only one door was argued.
Practical Tip: When meeting with an employment law attorney about disability discrimination or wrongful termination, make sure all three ADA definitions are evaluated. The best strategy may not be the most obvious one.
Best ADA Lawyer Blogs on Point:
What Does “Substantially Limits” Really Mean In ADA Disability Discrimination Cases?
This is where many employee claims fall apart.
The regulations say “substantially limits” should be “construed broadly” and “is not meant to be a demanding standard.” That sounds helpful for employees. But courts still require proof.
The Eighth Circuit Court of Appeals held that Stephens had to “prove a disability by offering evidence that the extent of the limitation caused by the impairment in terms of his own experience is substantial.” The Court also held that he could not rely on “generic ‘evidence of a medical diagnosis of an impairment.’”
Stephens argued that atrial fibrillation can cause shortness of breath and fainting. But the medical testimony showed he did not experience those symptoms. He was found medically fit to perform work that did not require a CDL. His stress test results were “unremarkable,” and he was described as “doing very well.”
Because the evidence did not show that his condition substantially limited breathing or cardiovascular function, the Eighth Circuit Court of Appeals held summary judgment was proper on his disability discrimination claim.
For an employee claiming wrongful termination or being wrongfully fired because of a health issue, this standard is critical. A diagnosis alone does not equal disability under employment law. Courts want evidence of real limitation.
Practical Tip: If you need a disability accommodation, document how your condition actually affects daily functioning. Specific examples strengthen a disability discrimination case and protect you if your employer later claims there was no real limitation.
Best Disability Discrimination at Work Attorney Blogs on Point:
Can I Be Fired Because My Boss Just Thinks I’m Disabled?
Here is a question employees ask all the time: what if I am functioning fine, but my employer overreacts?
The ADA includes protection for that situation. Under § 12102(1)(C), an employee is disabled if he is “regarded as having” an impairment. This focuses on the employer’s perception, not the employee’s level of limitation.
Stephens disclosed a heart condition. His employer required a medical exam. A nurse placed a 45-day hold on his CDL. Because his job required a CDL, that action prevented him from performing his position. Even though he was cleared to perform non-driving work, the employer denied that request.
Those actions show the employer restricted his job duties after learning of a medical condition.
The Eighth Circuit Court of Appeals did not analyze whether those actions satisfied the “regarded as” standard because Stephens abandoned that argument on appeal. The Court did not hold that the employer’s conduct was harmless. It simply did not reach that issue.
For employees facing disability discrimination or wrongful termination, this matters. An employer’s reaction can be just as important as the medical diagnosis itself. If your employer treats you as impaired and limits your work opportunities because of that belief, disability discrimination law may apply.
Practical Tip: If your employer removes duties, suspends licenses, or changes your role after learning about a condition, speak with an experienced employment lawyer immediately. Perceived disability can create legal protection even when symptoms are mild.
Best Workplace Disability Accommodation Law Firm Blogs on Point:
Is Asking For Safety Equipment The Same As Requesting Disability Accommodation?
Not always.
To succeed on ADA retaliation, an employee must show protected activity. The Eighth Circuit Court of Appeals held that “[r]equesting an accommodation is protected activity.” But the request must clearly relate to disability accommodation.
The Court held that Stephens’s respirator request was “actually a request for general safety equipment available to all employees.” He raised broad safety concerns. Only later did he mention his heart condition. He did not clearly state that he required a respirator because of his medical condition. His doctor had not instructed him to avoid confined spaces without one.
Because the request was framed as general safety rather than disability accommodation, the Court held he did not engage in protected activity. His ADA retaliation claim failed.
This is a critical employment law lesson. If you need something because of a disability, say that clearly. Otherwise, your employer may argue it was just a general complaint.
Practical Tip: Tie your request directly to your medical condition in writing. Clear communication strengthens a disability accommodation claim and protects against retaliation.
Best Employee’s Rights Attorney Blogs on Point:
Who Should I Call If I Was Wrongfully Fired Over A Medical Condition?
If you are an employee dealing with disability discrimination, denial of disability accommodation, or wrongful termination, do not assume any lawyer can handle it. Employment law is technical. Disability discrimination cases turn on definitions, medical records, timing, and how claims are framed.
A general practitioner who does not focus on employee rights may miss nuances like perceived disability, protected activity, or how wrongful termination intersects with discrimination law. Those details can determine whether an employer wins on summary judgment.
Spitz, The Employee’s Law Firm is one of the largest law firms in the United States dedicated to employees. We focus exclusively on employee rights. We offer free initial consultations, a no fee guarantee, and extensive trial experience. When an employer engages in discrimination or wrongfully fires an employee, strategy matters. If you believe you were wrongfully fired or denied a disability accommodation, call the best employment lawyer you can find. Call Spitz, The Employee’s Law Firm and speak with an attorney who fights for employees every day.
Employment Lawyer Disclaimer
This ADA employment blog provides general information about employment law, including disability discrimination, disability accommodation, wrongful termination, and situations where an employer may have wrongfully fired an employee. It is not legal advice. Reading this article does not create an attorney-client relationship with any attorney or lawyer at Spitz, The Employee’s Law Firm. Every employee’s case is different, and no promises are being made about the outcome of any discrimination or wrongful termination claim. This employee’s right blog is a legal advertisement. If you believe your employer has engaged in discrimination or denied disability accommodation, consult with a qualified employment law attorney to receive advice tailored to your specific situation.