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National Litigation Hotline

By ALM Staff | Law Journal Newsletters |
November 01, 2004

Mechanic Trainee Not an Employee for Purposes of Obtaining Relief Under ADA

The Fifth Circuit has held that the student of an automotive mechanical school who had dyslexia and attention deficit disorder lacked standing to bring an Americans with Disabilities Act (ADA) employment discrimination suit against the school where he was not in an employment relationship with either the school or the automotive manufacturer who provided funding for and developed the admissions policies and curriculum for the school. Brennan v. Mercedes Benz USA, 2004 WL 2224473 (Oct. 5, 2004).

After completing an entry-level automotive skills program offered by United Technical Institute of Texas, Inc. (UTI), in which he requested and obtained several accommodations for his disabilities, Plaintiff John Brennan was admitted into a more advanced training program offered by an affiliate corporation, Custom Training Group, Inc. (CTG), which focuses its training on automobiles from specific manufacturers. Brennan became a student of CTG's Mercedes Benz elite post-graduate training program, for which Mercedes provides funding, establishes admissions and failure standards, and develops a curriculum enabling its students to eventually obtain employment with a Mercedes Benz dealership. Admission into the elite program is not considered an offer of employment, and if graduates of the school desire to be employed by Mercedes they must apply for jobs with independent Mercedes Benz dealerships and service centers. Brennan was therefore never paid wages, benefits, or compensation from UTI, CTG, or Mercedes.

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