In a recent decision, a federal appellate court made a strong case for employers to prioritize accommodating employees over questioning whether they qualify as disabled under the Americans with Disabilities Act (ADA).
This case involved a physical therapist who experienced a miscarriage, which exacerbated her pre-existing PTSD, anxiety, and depression. After her employer denied her request to transfer to another location, it eventually terminated her for job abandonment.
Consideration of Major Life Activities Beyond Working
The district court, which entered summary judgment in favor of the employer, focused on whether the plaintiff’s mental health conditions substantially limited the plaintiff’s ability to work, concluding that the employee did not demonstrate that her impairment limited her ability to perform a class or broad range of jobs. However, the United States Court of Appeals for the Sixth Circuit found this myopic approach to be erroneous.
The plaintiff provided evidence that her PTSD and anxiety substantially limited her ability to sleep, care for herself and her children, concentrate, and interact with others, all of which the ADA contemplates. For example, following her miscarriage, she could not sleep, “function,” or care for her children. Since the district court failed to consider these limitations and erroneously focused solely on the plaintiff’s inability to work at one location, the Sixth Circuit reversed the entry of summary judgment for the employer.
Key Takeaways:
1. Broader Definition of Disability: The court emphasized that the ADA’s definition of disability is broad and includes impairments that are episodic in nature. The district court had erred by limiting its analysis to the major life activity of working and failing to consider other major life activities affected by the employee’s condition.
2. Personality Conflicts Aren’t the Issue: The employer argued that the employee’s issues were due to a personality conflict, which is not considered a disability under the ADA. However, the court found this argument unpersuasive, stating that it did not address the broader limitations on the employee’s major life activities. This serves as a reminder that employers should look beyond interpersonal conflicts and consider the overall impact of an employee’s condition.
3. Keep the Main Thing the Main Thing: For HR professionals and employment lawyers, the takeaway from this decision is clear: spend less energy debating whether an employee has a disability and more effort on ascertaining whether a reasonable accommodation exists that will enable them to perform the essential functions of their job without creating undue hardship on the business.