Americans with Disabilities Act, return to duty testing, disparate treatment, alcohol, refusal, due process, policy and procedure, public employee.

George Sadler files a discrimination against his former employer, the Southwest Alabama Mental Heath/Mental Retardation Board. Sadler argued that board officials violated provisions of the Americans with Disabilities Act when they terminated his employment. Sadler had received treatment for alcoholism on several occasions. Following a string of disciplinary actions related to Sadler's job performance, board officials ordered him to submit to regular drug testing as a condition for employment. Sadler complied with the testing requirement for a time, but eventually refused to submit to additional tests. Board officials subsequently terminated his employment.

This is the first judicial review of this case.

Sadler loses. The U.S. District Court for the Southern District of Alabama granted the board's motion for summary judgment. The court ruled that Sadler failed to demonstrate how he qualified for protection under the ADA and failed to prove that he was the victim of discrimination.