A terminated diabetic welder who became angry and aggressive as a result of low blood sugar posed a direct safety threat on the production floor, is not a “qualified individual” with a disability as defined by the Americans with Disabilities Act and is not eligible for ADA protection, a federal district court in Iowa rules.

The welder was terminated after a series of incidents where he lost control of his behavior due to low blood sugar—poor balance, swinging from equipment, staggering, threatening co-workers—and he subsequently filed a discrimination complaint based on his disability.

The court grants summary judgment to the employer, holding that the welder’s condition “posed an objective, direct threat to the health and safety of other employees” at the plant. “Various dangers were present on the production floor, such as welding arcs, cranes, hot metal, sparks, torches and forklifts,” the court says, continuing: “The Plant was full of dangers to a person who is unable to control his or her actions, and Plaintiff admits that when he is hypoglycemic, he is unable to control his actions. For instance, Plaintiff was observed staggering near his work station on the Plant floor. The Plant’s safety supervisor testified that he would not permit such a person on the production floor because that person’s presence would be potentially dangerous to others. Plaintiff has also admitted that he occasionally suffers from seizures or loses consciousness when he becomes hypoglycemic….If such an incident occurred while Plaintiff was welding, it could pose a direct threat to the safety of others.” Onken v. McNeilus Truck & Manufacturing Inc.