Labor & Employment Law Daily Wrap Up, DISCRIMINATION—DISABILITY—E.D. Mich.: Police officer on blood thinner was not qualified individual under the ADA, (Oct 14, 2025)

By Ursula Furi-Perry, J.D.

The officer was not a qualified individual under the ADA as his restricted activities after a heart attack were incompatible with essential police duties.

Granting summary judgment against a former police officer’s ADA and Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA) claims, a federal court in Michigan found he was not a qualified individual under the ADA, because his restricted activities after his heart attack were incompatible with essential police duties. Moreover, while the officer argued that he was denied promotion and subjected to harsher treatment than nondisabled colleagues, he offered no evidence that similarly situated nondisabled employees were treated more favorably (Reyna v. Hart, No. 2312790 (E.D. Mich. Oct. 9, 2025)).

Heart attack. The plaintiff worked as a police officer in Dearborn Heights, Michigan, since 2009; he was promoted to sergeant in 2017 and served in several roles, including detective. In 2020, he was appointed the department’s Accreditation Manager, a role that was primarily administrative and tied to departmental accreditation efforts. In March 2021, the officer suffered a heart attack and began taking blood thinners. Initially cleared for light duty, he was later allowed to return to work without restriction and continued as Accreditation Manager, despite subsequent diagnoses including atrial fibrillation.

Reassignment. In February 2022, a new police chief was hired, who paused the accreditation process citing compliance issues, and then reassigned the officer to uniformed road patrol. The officer provided a cardiologist’s note that prohibited assignments involving physical danger due to his blood thinner regimen. The chief concluded that the officer could no longer perform essential police duties and placed him on paid administrative leave with full pay and benefits, also suspending his law enforcement authority and firearm access. In 2023, the officer passed the lieutenant promotional exam and was the only eligible candidate, but the eligibility list expired without promotion.

The officer sued, alleging that the reassignment, suspension, and failure to promote constituted disability discrimination under the ADA and PWDCRA. He later sought to amend his complaint to add retaliation claims, arguing he was targeted for requesting accommodations, filing an EEOC charge, and speaking at a 2022 city council meeting. The defendants moved for summary judgment, arguing the officer was not a “qualified individual” under the ADA and failed to propose reasonable accommodations.

Failure to accommodate claim. The court found that the officer was not a qualified individual under the ADA. Police positions requiring MCOLES (Michigan Commission on Law Enforcement Standards) certification—even administrative roles—carry essential functions involving emergency response, confrontation, and potential exposure to harm, the court explained. The officer’s doctor explicitly restricted him from activities involving trauma, confrontation, or the risk of being shot, and that restriction was incompatible with essential police duties.

“At the hearing and in the motion, counsel explained every position requiring an MCOLES certification, even a job working at the front desk, requires that the employee participate in emergent situations,” the court reasoned. “For instance, an officer working the front desk at the precinct would need to respond if a violent situation arose inside the lobby or in the parking lot. Detectives, for example, must ‘run down leads,... come to crime scenes,’ which exposes the employee to risks of harm.”

While the officer argued that roles such as detective sergeant, support services, training sergeant, or administrative lieutenant could serve as accommodations, he failed to raise these options during employment discussions. Further, testimony established that all such positions required readiness to respond to dangerous incidents. The court emphasized that plaintiffs bear the burden of proposing specific, objectively reasonable accommodations, which the officer here failed to do.

Disparate treatment. The court next concluded that the officer also failed to establish disparate treatment. While he argued that he was denied promotion and subjected to harsher treatment than nondisabled colleagues, he offered no evidence that similarly situated nondisabled employees were treated more favorably. The lieutenant list expired without any promotions being made, and his claims of exclusion and hostility were unsupported by comparators or concrete examples.

The case is No. 23-12790.

Judge: Ivy, C., Jr.

Attorneys: Allexa Otto (Flood Law) for Joseph Reyna. Andrea Marie Pike (Rosati Schultz Joppich & Amtsbuechler) for Jerrod Hart and City of Dearborn Heights.

Companies: City of Dearborn Heights, Michigan

Cases: DisabilityDiscrimination Discrimination StateLawClaims MichiganNews