A recent ruling by the U.S. Court of Appeals for the Sixth Circuit serves as an important reminder that a plaintiff claiming protection under the Americans with Disabilities Act (ADA) must still prove that he or she has a covered disability, even under the 2008 amendments to the ADA, which significantly expanded its coverage.
The plaintiff in Booth v. Nissan North America, Inc. had injured his neck while on the job and was placed on work restrictions. Although the company accommodated his restrictions for over a decade, the plaintiff brought an ADA lawsuit in federal court alleging discrimination and failure to accommodate after he was denied a transfer because his restrictions conflicted with the job’s duties.
In affirming the trial court ruling, the Sixth Circuit found that the plaintiff’s claims failed on the merits, noting that “[s]imply having a work restriction does not automatically render one disabled.”
A copy of the Sixth Circuit’s opinion in Booth is available here.
Members of the Center for Workplace Compliance (CWC) can read more here.