The agency filed the underlying suit, EEOC v. The Carlstar Group, LLC, No. 3:25-cv-00575EJR, in May 2025 in the U.S. District Court for the Middle District of Tennessee. The EEOC said it first attempted to resolve the matter through its administrative conciliation process.

According to the EEOC's suit, since at least January 2020, Carlstar denied opportunities to manufacturing employees when it learned they were taking certain prescription medications, including narcotics and opioids, for the treatment of disabilities, even after the employees were medically cleared to perform their job duties. The suit also alleged that Carlstar failed to consider or provide reasonable accommodations to its drug testing and substance abuse policy that would have allowed employees to work while using their prescribed medications.

The agency said the alleged conduct violates the Americans with Disabilities Act, which prohibits disability discrimination in employment.

Beyond the monetary payment, the consent decree requires Carlstar to adopt policies and procedures for providing reasonable accommodations to employees taking prescription medication, train supervisors and other employees, track accommodation requests tied to prescription medication, post a notice about federal disability rights, and report periodically to the EEOC.

"Federal law provides protections for disabled employees who lawfully take prescription medication for qualifying disabilities," said Andrea G. Baran, regional attorney for the EEOC's St. Louis District Office. "Employers must follow the law, train their supervisors, and ensure they provide required accommodations to employees who take such medications and can perform the essential functions of their jobs."

David S. Davis, district director of the EEOC's St. Louis District Office, said, "Compliance with the ADA requires more than a one-size-fits-all approach. Employers must individually assess such employees to determine whether they can safely perform their job duties while taking the medication."