Donahue v. Union Pacific Railroad Company

CourtDistrict Court, N.D. California
DecidedMay 13, 2025
Docket3:21-cv-00448
StatusUnknown

This text of Donahue v. Union Pacific Railroad Company (Donahue v. Union Pacific Railroad Company) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Donahue v. Union Pacific Railroad Company, (N.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 IN THE UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 10 JUSTIN DONAHUE, et al., Case No. 21-cv-00448-MMC

11 Plaintiffs, GRANTING DEFENDANT'S MOTION 12 v. FOR SUMMARY JUDGMENT

13 UNION PACIFIC RAILROAD Re: Dkt. No. 60 COMPANY, 14 Defendant. 15 16 Before the Court is defendant Union Pacific Railroad Company’s (“Union Pacific”) 17 “Motion for Summary Judgment” (Doc. No. 60), filed August 5, 2022. Plaintiffs Justin 18 Donahue ("Donahue"), Jason Campbell ("Campbell"), and Jacob Goss ("Goss") have 19 filed opposition, to which Union Pacific has replied. Having read and considered the 20 papers filed in support of and in opposition to the motion and having considered the 21 arguments made at hearing, the Court rules as follows. 22 23 BACKGROUND 24 Plaintiffs are three former conductors1 for Union Pacific (see Rhoten Decl. Ex. B 25 (Goss), Ex. C (Campbell), Ex. D (Donahue)) whose positions “entailed reading and 26 interpreting multicolored railroad traffic signal lights on signal masts” (see Compl. ¶¶ 30, 27 1 44, 57; see also Rhoten Decl. Exs. E, F). Plaintiffs were each "responsible for train 2 movement" and, consequently, each was required to be "certified by the Federal Railroad 3 Administration.” (See Compl. ¶ 2). 4 As part of the certification process, the Federal Railroad Administration “prescribes 5 minimum Federal safety standards” that conductors and locomotive engineers must meet 6 to hold such positions, see 49 C.F.R. §§ 240.1, 242.1, including “[t]he ability to recognize 7 and distinguish between the colors of railroad signals," see 49 C.F.R. §§ 240.121(c)(3), 8 242.117(h)(3). Union Pacific recertifies conductors and locomotive engineers every three 9 years, in accordance with FRA regulations. (See McClelland Decl. ¶ 4). 10 In 2016, 2017, and 2018, respectively, Goss, Donahue, and Campbell took and 11 failed the two tests administered by Union Pacific in those years, namely "the 14-Plate 12 Ishihara test" ("Ishihara") and a color vision field test known as the “Light Cannon” (see 13 Compl. ¶¶ 3, 26, 33-34, 47, 49, 61-62). As a result, Union Pacific issued plaintiffs 14 “permanent work restrictions” prohibiting them from working as conductors or locomotive 15 engineers. (See Compl. ¶¶ 37, 50, 63). Plaintiffs challenge their work restrictions on the 16 alleged ground that the Light Cannon test “does not assess the employee’s ability to 17 recognize and distinguish between colors of railroad signals.” (See Compl. ¶ 27). 18 Based on the above, plaintiffs assert two claims under the Americans with 19 Disabilities Act (“ADA”), specifically, Count I, titled "Disability Discrimination - Disparate 20 Treatment," and Count II, titled "Disability Discrimination – Disparate Impact."2 21 By the instant motion, Union Pacific seeks summary judgment, on the asserted 22 grounds that (1) plaintiffs’ disparate impact claim is time-barred, (2) both claims are 23 precluded by the Federal Railroad Safety Act, 49 U.S.C. § 20100 et seq., and (3) both 24 claims fail on their merits. 25 26

27 2 By order filed June 16, 2022, the third claim asserted in the Complaint, titled 1 LEGAL STANDARD 2 Pursuant to Rule 56 of the Federal Rules of Civil Procedure, a "court shall grant 3 summary judgment if the movant shows that there is no genuine issue as to any material 4 fact and that the movant is entitled to judgment as a matter of law." See Fed. R. Civ. P. 5 56(a). 6 The Supreme Court's 1986 "trilogy" of Celotex Corp. v. Catrett, 477 U.S. 317, 106 7 S. Ct. 2548, 91 L. Ed. 2d 265 (1986), Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 106 8 S. Ct. 2505, 91 L. Ed. 2d 202 (1986), and Matsushita Electric Indus. Co. v. Zenith Radio 9 Corp., 475 U.S. 574, 106 S. Ct. 1348, 89 L. Ed. 2d 538 (1986), requires that a party 10 seeking summary judgment show the absence of a genuine issue of material fact. Once 11 the moving party has done so, the nonmoving party must "go beyond the pleadings and 12 by [its] own affidavits, or by the depositions, answers to interrogatories, and admissions 13 on file, designate specific facts showing that there is a genuine issue for trial." See 14 Celotex, 477 U.S. at 324 (internal quotation and citation omitted). "When the moving 15 party has carried its burden under Rule 56[ ], its opponent must do more than simply 16 show that there is some metaphysical doubt as to the material facts." Matsushita, 475 17 U.S. at 586. "If the [opposing party's] evidence is merely colorable, or is not significantly 18 probative, summary judgment may be granted." Liberty Lobby, 477 U.S. at 249-50 19 (citations omitted). "[I]nferences to be drawn from the underlying facts," however, "must 20 be viewed in the light most favorable to the party opposing the motion." See Matsushita, 21 475 U.S. at 587 (internal quotation and citation omitted). 22 23 DISCUSSION 24 A. Disparate Impact Claims 25 By order issued September 16, 2022, the Court granted summary judgment in 26 favor of defendant as to both the disparate treatment and disparate impact claims, on the 27 basis that both were time-barred, finding plaintiffs’ ability to rely on “the equitable tolling 1 under which the filing of a class action tolls the statute of limitations as to all asserted 2 members of the class” (see Order Granting Summary Judgment at 4:15-19) (internal 3 quotation and citation omitted), ended when the named plaintiffs in Harris v. Union Pacific 4 Railroad Co., Case No. 16-cv-381-JFB-SMB, the putative class action on which plaintiffs 5 relied, voluntarily abandoned their disparate impact claims and narrowed the class 6 definition as to their disparate treatment claims. 7 Plaintiffs appealed, and, on June 14, 2024, the Ninth Circuit reversed and 8 remanded the action. See Donahue v. Union Pac. R.R. Co., No. 22-16847, 2024 WL 9 2988223 (9th Cir. June 14, 2024). On appeal, however, plaintiffs chose to “pursue only 10 their disparate treatment theory.” See Donahue, Campbell, & Goss v. Union Pac. R.R. 11 Co., No. 22-16847, Dkt. 25 at 15 n.1 (9th Cir. May 5, 2023). In light of such election by 12 plaintiffs, their disparate impact claims were not addressed by the Ninth Circuit. In 13 particular, the Memorandum decision issued in the instant case incorporated the 14 reasoning of DeFries v. Union Pac. R.R. Co., 104 F.4th 1091 (9th Cir. 2024), one of three 15 cases argued to the panel on the same date and in which the plaintiffs therein were 16 “situated identically.” See Donahue, 2024 WL 1988223, at *3. 17 In DeFries, the plaintiff, like the plaintiffs here, did not pursue his disparate impact 18 claim on appeal, electing to proceed solely on his disparate treatment claim. See 19 DeFries v. Union Pac. R.R. Co., No. 23035119, Dkt. 14 at 14 n.3 (9th Cir. May 24, 2023).

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Donahue v. Union Pacific Railroad Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donahue-v-union-pacific-railroad-company-cand-2025.