Fiat Chrysler Applicants With Dwarfism Lose ADA Claims

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By Jay-Anne B. Casuga

June 13 — Two applicants with achondroplasia dwarfism who weren't selected for production jobs at a Fiat Chrysler plant in Michigan can't proceed with federal or state law disability bias claims, a federal judge ruled ( Snyder v. Chrysler Grp., LLC , 2016 BL 185903, E.D. Mich., No. 15-12238, 6/10/16 ).

The case offers an example of applicants failing to show they are qualified individuals with disabilities entitled to protection under the Americans with Disabilities Act and Michigan's Elliott-Larsen Civil Rights Act. A qualified individual within the meaning of the two laws is someone who can perform a job's essential functions with or without a reasonable accommodation for his or her disability.

Matthew Vallelunga and Thomas Snyder failed to make such a showing because neither obtained the proper scores in a two-part hiring assessment, Judge Thomas L. Ludington of the U.S. District Court for the Eastern District of Michigan held June 10, granting summary judgment to FCA US LLC.

The company's hiring process requires applicants to pass an Automated Production Simulation test, which involved performing automotive manufacturing tasks and processes such as mounting, assembling and bolting parts, the court said.

FCA also requires applicants to take a “computer-based, multi-format, multiple-choice test” called the Team Member Career Battery, which measures applicants' decision making, personal competence, and self-management and interpersonal skills.

Applicants have to score above the 20th percentile in both portions of the test to be considered qualified for production team member positions.

Vallelunga, the court said, passed the APS test, demonstrating that he was able to perform the physical tasks of the position. However, he didn't score high enough on the TMCB test. Snyder didn't score above the 20th percentile in either portion of the two-part evaluation, the court said.

As such, neither Vallelunga nor Snyder demonstrated that they were qualified under the ADA or the ELCRA for the positions they sought, the court ruled.

Gold Star Law represented the applicants. Ogletree Deakins represented FCA.

To contact the reporter on this story: Jay-Anne B. Casuga in Washington at

To contact the editor responsible for this story: Susan J. McGolrick at