Scheffler v. Dohman

In 1997, after his third DWI arrest, Scheffler’s driving privileges were cancelled. Scheffler successfully completed a one-year abstinence-only program, and in 1998, was issued a driver’s license with the restriction that he abstain from use of alcohol. After a 1999 cancellation of his license, Scheffler was completed a three-year rehabilitation program and received a restricted license in 2002. In 2010, Scheffler was arrested for DWI and, to obtain a new restricted license, had to either complete a six-year rehabilitation program or submit to an Ignition Interlock Program. Scheffler sued, claiming Americans with Disability Act violations based on perceived alcoholism. The district court dismissed. The Eighth Circuit affirmed. ADA defines a disabled person as having a physical or mental impairment that substantially limits one or more major life activities, having a record of such an impairment, or being regarded as having such an impairment, 42 U.S.C. 12102(1). Alcoholism may qualify when it limits a major life activity. Scheffler did not claim to actually be an alcoholic or that alcoholism limits a major life activity. DWI does not, alone, establish that he is an alcoholic. There was no allegation that Scheffler has ever been diagnosed as an alcoholic or that Scheffler suffers from a substantial limitation to a major life activity. View "Scheffler v. Dohman" on Justia Law