Opioids, Narcotics, Job Descriptions, And Reasonable Accommodations

Written exclusively for Chubbworks

The EEOC alleges that The Carlstar Group, LLC, a Tennessee-based manufacturer of specialty tires and wheels, unlawfully discriminated against employees at facilities in Clinton and Jackson, Tennessee, and Aiken, South Carolina. The complaint contains allegations that the company denied job opportunities and terminated workers who lawfully used medications including narcotics and opioids. The EEOC seeks back pay, damages, and changes to company practices on behalf of employees.

The EEOC alleges the company's employment actions and its drug-testing or qualification standards as applied to workers with disabilities violates the Americans with Disabilities Act.

The lawsuit was filed in federal court in Tennessee in May 2025.

Source: https://www.eeoc.gov/newsroom/eeoc-sues-carlstar-disability-discrimination

Commentary

Legally-prescribed medications, including narcotics and opioids used to treat disabilities such as anxiety, depression, ADHD, and other covered conditions, do not automatically mean a worker cannot perform the job safely and effectively.

The correct focus is on whether the person can perform the essential functions of the position, with or without reasonable accommodation, rather than on assumptions about a diagnosis or prescribed treatment.

Through an interactive process, an employer can work with the employee, the job description, and the treating physician to assess whether an employee can perform the job. A job description can be helpful when it clearly identifies the essential functions, physical demands, cognitive expectations, schedule requirements, travel, lifting, driving, supervision, and any safety-sensitive duties.

If the description is vague or outdated, the medical opinion may be less useful and the employer may face unnecessary conflict over what the job requires. Clear job descriptions also help employers evaluate accommodation requests, return-to-work decisions, and fitness-for-duty issues in a consistent and defensible way.

As a result, employers should update job descriptions regularly so they reflect current operations, technology, staffing, and safety expectations. When descriptions are accurate, physicians can better assess work capacity, managers can make better decisions, and employers can reduce the risk of discrimination claims, inconsistent treatment, and poor documentation.

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