The Eighth Circuit Court of Appeals affirmed summary judgment for United States Environmental Services LLC in *Donald Stephens v. United States Environmental Services LLC*, ruling that a former employee who disclosed a heart condition at work was not disabled under federal law and did not engage in protected activity.
Donald Stephens worked as an operator for USES, a position requiring him to maintain an active Commercial Driver's License. The case arose from events on Feb. 27, 2021, when Stephens reported to a worksite for a Saturday morning shift to clean out two underground tanks.
When Stephens arrived at the worksite, only the supervisor, Terry, was present. Terry informed Stephens that a technician and two safety workers were coming, but after Stephens finished setting up his truck, they still had not arrived. As Terry grew impatient, he asked Stephens to start cleaning out the first tank.
Stephens declined the request, explaining that he was a truck operator, not a technician. He also raised multiple safety concerns, including the absence of safety workers and safety equipment. During this exchange, Stephens disclosed to Terry that he had a heart condition.
In response to this disclosure, USES required Stephens to undergo a medical examination. The examination resulted in a 45-day hold being placed on Stephens's CDL, effectively preventing him from performing his primary job duties as an operator.
Stephens then requested that USES assign him to work that did not require a CDL during the 45-day hold period. The company denied this request, leading Stephens to resign from his position.
Following his resignation, Stephens filed a lawsuit against USES alleging disability discrimination and retaliation under federal employment law. He argued that the company's actions following his heart condition disclosure violated his rights under the Americans with Disabilities Act.
The case proceeded through the U.S. District Court for the Eastern District of Arkansas - Central Division, where USES moved for summary judgment. The district court granted the company's motion, finding that Stephens was not disabled under the ADA and had not engaged in protected activity that would support his retaliation claims.
Stephens appealed the district court's decision to the Eighth Circuit Court of Appeals. The three-judge panel, consisting of Chief Judge Colloton and Circuit Judges Shepherd and Erickson, heard the case after it was submitted on Nov. 19, 2025.
In an opinion authored by Circuit Judge Erickson and filed on Feb. 12, 2026, the Eighth Circuit affirmed the district court's grant of summary judgment in favor of USES. The appeals court agreed with the lower court's determination that Stephens was not disabled within the meaning of federal disability discrimination law.
The court's analysis focused on whether Stephens's heart condition constituted a disability under the ADA's definition, which requires that an individual have a physical or mental impairment that substantially limits one or more major life activities. The court also examined whether Stephens's disclosure of his heart condition and subsequent requests for accommodation constituted protected activity under federal employment law.
The ruling represents the Eighth Circuit's interpretation of disability discrimination law in the context of CDL requirements and workplace safety protocols. The case highlights the intersection between federal transportation safety regulations and employment discrimination protections.
For employers in the transportation industry, the decision provides guidance on how courts evaluate disability claims when employees voluntarily disclose medical conditions that may affect their ability to maintain required licenses or certifications.
The case also illustrates the challenges faced by workers who must balance workplace safety concerns with employment security, particularly in positions requiring specialized licenses or certifications.
USES successfully defended against both the discrimination and retaliation claims, with the court finding that the company's actions following Stephens's disclosure were legally justified and did not violate federal employment protections.
The Eighth Circuit's decision is final unless Stephens chooses to petition the Supreme Court for review, though the high court accepts only a small fraction of such petitions for full consideration.
This case adds to the body of federal appellate precedent interpreting the scope of disability protections in transportation-related employment, where safety regulations often intersect with anti-discrimination laws. The ruling may influence how similar cases are handled in the Eighth Circuit's jurisdiction, which covers Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota.