The Second Circuit Court of Appeals has ruled that a medical condition related to the working environment surrounding a specific job is not considered a substantial impairment on the employee’s ability to work. The case was brought by an employee who claimed he suffered discrimination under the Americans with Disabilities Act (ADA) after he was fired due to poor job performance. The court agreed with the defendant that the inability to perform a single, specific job is not the same as having a substantial impairment on the ability to work entirely.
In Woolf v. Strada, the plaintiff claimed he suffered migraines due to work-related stress, resulting in a decline in his work performance. He requested multiple transfers to attempt to address the situation, but was denied those transfers, ironically as a result of his poor work performance. He continued to suffer from the migraines, and subsequently was dismissed from his job. The plaintiff sued for discrimination under the ADA, claiming his employer discriminated against him for his medical condition and failed to make reasonable accommodations to assist in dealing with his migraines.
The court recognized that the plaintiff indeed suffered from stress-related migraines, and that those migraines could be considered a disability that might result in substantial impairment under certain circumstances. However, the Second Circuit ultimately ruled that, under the ADA, a disability must prohibit an employee from working in “a class or broad range of jobs,” and not merely a single, specific position. Because the plaintiff failed to allege his migraines impaired his ability to work in a class or broad range of jobs, and only that it impaired his ability to work in that one position, his claim of disability discrimination was dismissed.
If you believe you are the victim of employment discrimination, contact the Law Office of Andrew Ross Sack. Mr. Sack will protect your rights and strive to bring the relief you deserve. Give him a call at (516) 526-3319, or visit his contact page.
