From time to time, we encounter requests from employees for accommodations under the Americans with Disabilities Act that appear unrelated to the employee’s underlying medical condition. For example, an employee with a back condition will request reassignment of duties that require accurate inventory counts. In a new decision, the Seventh Circuit Court of Appeals confirmed that the employer’s accommodation obligations only apply to work limitations caused by the disabling medical condition.
In Youngman v. Peoria County, the plaintiff suffered from hyperthyroidism. He worked for a juvenile detention facility and claimed that the noises and images from cameras and monitors in the control room caused motion sickness, headaches, and dizziness. He requested an accommodation that would allow him to avoid working in this area. After he took FMLA leave, the employer concluded that the plaintiff could not perform his essential job functions without working in the control room. He sued under the ADA, alleging the employer failed to provide a reasonable accommodation.
The Seventh Circuit affirmed dismissal of the suit on summary judgment. The court noted deposition testimony from the plaintiff’s doctor denying a connection between hyperthyroidism and the plaintiff’s control room symptoms. Even though he undoubtedly suffered from an ADA covered disability, in order to claim entitlement to an accommodation, the employee must show a causal connection between that medical condition and problems experienced at work.
Although employers should not play doctor by assuming the lack of such connection, as part of the ADA interactive process, they can ask the employee for more detailed medical information establishing this link.
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