Pollard v. Union Pacific Railroad Co.

CourtDistrict Court, D. Nebraska
DecidedSeptember 15, 2025
Docket4:21-cv-03124
StatusUnknown

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

Bluebook
Pollard v. Union Pacific Railroad Co., (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

CHARLES WALDSCHMIDT, and NANCY POLLARD, as Personal representative of CHARLIE GRIGG; 4:21CV3124 8:22CV210 Plaintiffs,

vs. MEMORANDUM AND ORDER

UNION PACIFIC RAILROAD CO.,

Defendant.

This case is brought on behalf of a putative class of hearing-impaired employees, former employees, and applicants for employment with Defendant, Union Pacific Railroad Company. Plaintiffs allege Union Pacific violated the Americans with Disabilities Act when it implemented various policies affecting hearing-impaired workers. The case comes before the Court on Plaintiffs’ motion to certify class, Filing No. 175, and Defendants’ motion to extend progression order deadlines, Filing No. 220. I. BACKGROUND The ADA prohibits covered employers from “discriminat[ing] against a qualified individual on the basis of disability” with respect to the terms and conditions of employment. 42 U.S.C. § 12112(a). The ADA provides a three-pronged definition for determining when an individual is disabled: The term ‘disability’ means, with respect to an individual—

(A) a physical or mental impairment that substantially limits one or more major life activities of such individual;

(B) a record of such an impairment; or

(C) being regarded as having such an impairment 42 U.S.C. § 12102. The ADA defines “qualified individual” as “an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8). Essential functions are the “fundamental job duties of the employment position.” 29 C.F.R. § 1630.2(n)(1). Discrimination also includes the use of “qualification standards, employment tests, or other selection criteria that screen out or tend to screen out an individual with a disability.” 42 U.S.C. § 12112(b)(6). Qualification standards include “medical, safety and other requirements established by [an employer] as requirements . . . to be eligible for the

position held or desired.” 29 C.F.R. § 1630.2(q). An employer has an affirmative defense to a charge of discrimination for qualification standards that deny job benefits to individuals with disabilities if the standards are “shown to be job-related for the position in question and . . . consistent with business necessity.” 42 U.S.C. § 12113(a). Plaintiffs are Train, Engine & Yard (TE&Y) employees, commonly known as train crew or trainmen (or applicants for those positions), with Union Pacific. Filing No. 177-1; Filing No. 177-2. Union Pacific implemented a set of hearing-protection and hearing- testing policies that applied to all TE&Y employees. In many cases, these policies exceed the safety procedures implemented by the Federal Railroad Administration’s regulations. For example, Union Pacific requires TE&Y employees to wear hearing protection when

working within 150 feet of a locomotive or in a locomotive with the windows open. Filing No. 177-3 at 7. However, the FRA only requires hearing protection when the 8-hour time- weighted average hits of exceeds 90 decibels with a doubling rate of 5 decibels.1 49 C.F.R 227.115(d). Union Pacific’s noise-monitoring data shows that of a hundred TE&Y employees, none were exposed to sound at a level that would require hearing protection under the FRA since the year 2001. Filing No. 178-3. For example, from 2011 through 2017, TE&Y employees were exposed to an average 8-hour time-weighted average of

79.13 decibels. Filing No. 178-3. Union Pacific policy also requires all TE&Y employees to wear hearing protection devices that it approved. Filing No. 177-3 at 2–3, Filing No. 178-2 at 57–58. Union Pacific only approves hearing protection that has a manufacturer-issued Noise Reduction Rating (NRR). Filing No. 178-2 at 58–59. The company will not modify the policy as an accommodation to disabled workers, including allowing custom-made hearing protection. Filing No. 177-14 at 88–90, Filing No. 177-6 at 2403. This is in contrast to the FRA which declined to mandate the use of NRR for hearing protection. See 71 Fed. Reg. at 63,083 (“The [noise exposure] Working Group discussed these comments and expressed

concern that replacing that phrase with the NRR (or any other specific indicator) would ultimately be limiting. It would prevent the industry from availing themselves of advances in science and technology. By not listing any particular indicator, FRA leaves it open for the development of new standards.”). Union Pacific also implemented policies specific to hearing-impaired individuals. For example, it requires employees who wear hearing aids to remove their hearing aids

1 Time-weighted average “means the sound level, which, if constant over 8 hours, would result in the same noise dose as is measured.” 49 C.F.R. § 227.5. The doubling rate “means the change in sound level, in decibels, which would require halving or doubling of the allowable exposure time to maintain the same noise dose.” Id. So, this means that a worker could be exposed to 90 decibels for 8 hours, or 95 decibels for only 4 hours, or 100 decibels for 2 hours. See 49 C.F.R. Pt. 227, App. A (noise exposure computation chart). and instead wear amplified hearing protection devices (AHPDs) when hearing protection is required, even if their doctors recommend otherwise. Filing No. 178-2 at 5. Union Pacific approved only certain brands of AHPD. Filing No. 177-4; Filing No. 178-2 at 5. By contrast, the FRA regulations permit employees to wear hearing aids under AHPDs. See 49 C.F.R § 227.115(a)(4); Filing No. 177-8 at 2–3.

In conjunction with these hearing policies, Union Pacific also implemented a hearing testing protocol. It required all TE&Y employees to undergo and pass a hearing test at the outset of their employment and every three years. Filing No. 178-2 at 12. The protocol is a two-step process. First, all TE&Y employees are required to take a hearing exam demonstrating they do not have hearing loss in their better ear greater than 40 decibels. Filing No. 177-14 at 144–48, 159–60; Filing No. 178-2 at 12. If an employee wears hearing aids, he or she must remove them for this first-round test. Filing No. 177- 14 at 122–28, 138–41. If an employee cannot pass the first round of testing with unaided hearing, Union Pacific defers deciding that employee’s fitness for duty pending further

testing. Filing No. 177-14 at 159–60; Filing No. 179-3. This often results in the employee being held out of service or forced into temporary roles pending additional testing. Filing No. 177-14 at 141–58. The second-round test is performed by an audiologist using Union Pacific’s standardized instructions and form. Filing No. 177-14 at 159–60; Filing No. 179-3.

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