Jason Schmit drove trucks for Trimac Transportation Inc. out of its Rapid City, South Dakota terminal from May 2017 to August 2021, earning accommodations for his Parkinson's disease diagnosis in December 2018. The company informally allowed him to haul rock and coal loads that didn't require climbing ladders, arranged for trailer washouts, gave him a five-day work week ending by 1:00 p.m., and permitted him to 'haul light' when symptoms flared. When Gene Williams became terminal manager in March 2021, he formalized these accommodations but later denied additional requests, leading to Schmit's departure in August 2021.
The Eighth Circuit affirmed U.S. District Judge Charles B. Kornmann's grant of summary judgment for Trimac, finding Schmit failed to show he was a 'qualified individual' under the ADA. As Circuit Judge Kobes wrote, 'Schmit told the SSA, and so conceded, that he suffered from debilitating Parkinson's symptoms, from serious medication side effects, and that it was 'impossible' for him to work because of his condition.' The court emphasized that while statements to Social Security don't automatically preclude ADA suits, plaintiffs must offer 'a sufficient explanation' for apparent contradictions between disability benefit claims and employment discrimination suits.
The panel delivered particularly sharp criticism of Schmit's inconsistent positions, noting he 'swore under penalty of perjury that he suffers from 'hallucinations & delusions' and it was 'impossible' for him to work because he couldn't 'control [his] right hand, arm, right leg & foot.'' Circuit Judge Kobes added that 'a person who applied for disability benefits must live with the factual representations made to obtain them, and if these show inability to do the job then an ADA claim may be rejected without further inquiry.'
The case reached the Eighth Circuit after Kornmann, sitting in the District of South Dakota, dismissed Schmit's state law claims for failure to exhaust administrative remedies and granted Trimac's summary judgment motion on his federal ADA claims. While the district court found genuine disputes about whether Schmit resigned or was fired and whether Trimac had discriminatory attitudes, it concluded his Social Security representations barred recovery. Schmit had applied for total Social Security benefits on August 18, 2021, stating he 'became unable to work because of my disabling condition on August 7, 2021.'
Schmit argued there was no contradiction because he could be 'qualified' under the ADA with reasonable accommodations while still disabled for Social Security purposes, which doesn't consider accommodation possibilities. The court acknowledged this general principle but distinguished Schmit's case, explaining he 'did not just say he has a disability. Nor that he was merely 'unable to work.' He swore under penalty of perjury that he suffers from 'hallucinations & delusions' and it was 'impossible' for him to work.' The panel found these specific factual representations incompatible with performing essential job functions.
The court also rejected Schmit's hostile work environment and retaliation claims, finding his allegations of harassment by Williams—including references to his 'limited' work capacity and threats to 'get rid of him'—amounted to 'ordinary tribulations of the workplace' rather than severe or pervasive conduct. On retaliation, Circuit Judge Kobes noted that the four-month gap between Schmit's accommodation request and his termination was insufficient to establish causation, as 'temporal proximity between the protected conduct and adverse action 'must be very close' for timing alone to be sufficient.'
For practitioners, the decision reinforces the continuing tension between ADA 'qualified individual' requirements and Social Security disability determinations, particularly when applicants make specific factual representations about their functional limitations. The ruling suggests courts will closely scrutinize sworn statements to federal agencies that appear to contradict employment discrimination claims, requiring plaintiffs to provide compelling explanations for apparent inconsistencies rather than relying on general legal distinctions between the two regulatory schemes.