When reviewing an employee’s request for accommodations under the Americans with Disabilities Act, employers sometimes develop tunnel vision when deciding whether the claimed medical condition constitutes a protected ADA disability. A new decision from the Sixth Circuit Court of Appeals cautions employers to look beyond the impacts of the medical condition on the employee’s job.
In Simon v. University Hospitals Cleveland Medical Center, the plaintiff suffered a miscarriage and requested a transfer from her position due to post-traumatic stress disorder, anxiety, and depression. The case predates the Pregnant Workers Fairness Act, which would have provided an additional statutory claim. She based her request for the transfer on alleged conflicts with coworkers who spread rumors about the reasons for her medical leave. The employer concluded that the accommodation request involved a personal conflict with coworkers and that the plaintiff was not disabled because she was able to work in an environment that did not have these conflicts. The district court agreed, dismissing the case on summary judgment.
On appeal, the Sixth Circuit disagreed, remanding the case to the district court. The appellate court said that the ADA protects medical conditions that substantially interfere with a major life activity. Those activities are not limited to the impact of the condition on work, and the district court failed to analyze how the plaintiff’s condition affected other aspects of her life.
When reviewing employee accommodation requests, employers sometimes limit their focus to the effects of the medical condition on the employee’s job. Even if the alleged disability does not limit the employee from the major life activity of working, they can still be entitled to accommodations if the measures are needed to accomplish their particular job. This requires a holistic evaluation of the impact of the condition on the employee’s life. The legal bar for a protected disabling medical condition under the ADA is low. In most cases, employers considering accommodation requests should assume that the condition rises to the level of an ADA disability and focus on whether the request is reasonable and effective instead of concluding that it does not meet the requirements for ADA coverage.
For more information, please contact me or your regular Parker Poe contact. You can also subscribe to our latest alerts and insights here.