The United States Supreme Court applied the Sutton analysis
in the companion case of Murphy v. U.P.S. Murphy was a mechanic for U.P.S. As
part of his job, he was required to drive the trucks which were brought in for
service. To do this, he had to have a commercial truck drivers license and meet
Department of Transportation (DOT) medical standards. He could not do this because
he had hypertension and even with medication it was higher than the DOT standard.
The court found, however, that this hypertension did not affect any significant
life activities. As with Sutton, the fact that plaintiff could work as a mechanic,
just not for UPS, did not meet the standard for interfering with the life activity
of working. The court thus found that plaintiff was not disabled and could not
sue under the ADA.
Murphy is more troubling than Sutton in that hypertension that
exceeds DOT standards even with medication can interfere with many of plaintiff's
life functions. If HIV was a disability in Bragdon because it interfered with
the decision to have children in a plaintiff who said she never wanted children,
it would seem that the cardio-vascular damage caused by inadequately treatable
hypertension would interfere with plaintiff's ability to live a natural life
span and be free of many diseases. The court might have ignored this because
it was not properly developed by plaintiff's petition. The plaintiff also failed
to raise his strongest issue: whether driving trucks (and thus needing DOT certification)
is an essential job function for a mechanic.
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