Anxiety – Not Enough for an ADA Claim
A Federal District Court Judge in Tennessee recently ruled an anxious employee did not have a disability under the Americans with Disabilities Act (“ADA”). For HR professionals, this news likely comes as a surprise since the definition of disability keeps expanding under recent amendments to the ADA.
Here’s what the Court said.
In January 2018, the Equal Employment Opportunity Commission (“EEOC”), the federal watchdog for anti-discrimination employment statutes, brought a lawsuit against the Health Care Center at West Meade Place alleging a disability discrimination claim under the ADA. The EEOC argued the employer failed to accommodate a laundry technician’s request for intermittent leave due to anxiety and terminated her employment after she made the request.
The Court denied her ADA claim finding she failed to put forth evidence that her anxiety rose to the level of a mental impairment that substantially limits a major life activity, a key requirement of a disability under the ADA. The employee herself supported this conclusion when she testified while she had anxiety, it in no way limited her ability to do her job. With such testimony, the Court had no option but to find for the employer.
While this case is only persuasive authority in jurisdictions outside of Tennessee, it does serve as a good reminder for employers that all ADA cases are not a losing battle (as often employers fear). However, employers in States like Connecticut and New York which have expansive disability protections on the State level should tread cautiously as a State or local administrative agency might reach an alternate result than the Tennessee District Court Judge.
Brody and Associates regularly provides counsel on the ADA, as well as other civil rights issues and employment laws in general. If we can be of assistance in this area, please contact us at firstname.lastname@example.org or 203.454.0560.
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