Sixth Circuit: Work Restrictions Do Not Equate to a Disability Under the ADA

In Booth v. Nissan North America, Inc., the Sixth Circuit stated that just because an employee has physical work restrictions does not equate to being “disabled” under the Americans with Disabilities Act (ADA). A person is disabled under the ADA if they have a (1) “physical or mental impairment that substantially limits one or more major life activities,” (2) “a record of such impairment,” or (3) is “regarded as having such an impairment.”

There, an employee had work restrictions, was denied a transfer to a position the employee claimed was easier for him to perform, and instead was asked to work in a more rigorous role; however, he remained working in the same assembly line role during this period. The court noted that “working” is an example of a major life activity, and the employee must still show that his impairment limits his ability to perform a class of jobs or broad range of jobs, not just one specific job. The employee worked in a two-job position on an assembly line and questioned whether his restrictions permitted him to work in a more rigorous four-job position that the employer wanted him to perform on an assembly line. He was still able to work in an assembly line setting and was only questionably limited in one specific job. The court stated that the possible limitations on one specific job were insufficient to establish being disabled under the ADA.

Although this distinction may be helpful to employers, they must still be vigilant in adhering to ADA requirements. It is best practice to involve legal counsel before denying any disability-based accommodation request.

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