Generally, circumstances dictate whether an employer has to eliminate driving from an employee’s job duties. If driving is an essential function of a job, an employer does not have to eliminate it. However, an employer should carefully consider whether driving actually is an essential job function, a marginal job function, or simply one way of accomplishing an essential function. If an accommodation is available that would enable an employee with epilepsy to perform a function that most employees would perform by driving, then the employer must provide the accommodation, absent undue hardship. Similarly, if driving is a marginal (or nonessential) function, the fact that an individual with epilepsy does not have a driver's license cannot be used to deny the individual an employment opportunity.
In Bradley’s case, driving is not an essential function of his job. Not every guide is asked to drive prospective students to and from the airport, and there are always other guides available to perform the function if a particular individual is unavailable. Because driving is not an essential function of the job, the college cannot refuse to hire a person to be a guide who does not have a driver's license because of epilepsy; rather, it would have to assign someone else to perform that task.
Source: EEOC Publication: Revised Questions and Answers about Epilepsy in the Workplace and the Americans with Disabilities Act, reported in Employment Practices Guide, ¶5373.