Under the Americans with Disabilities Act, plaintiffs have the burden of demonstrating they have a disability that results in a significant impairment of a major life activity. Since adoption of the ADA Amendments Act (ADAAA) in 2009, the amount of litigation over the question of disabled status has diminished. However, defendants still occasionally challenge ADA suits on the basis that the plaintiff fails to meet the definition of a protected disabled individual. Last month, the First Circuit Court of Appeals found that plaintiffs can meet this burden even in the absence of medical information regarding their condition.
In Mancini v. City of Providence, the plaintiff had a knee injury and claimed that the city’s police department failed to promote him because of his medical condition. The district court granted the employer’s motion of summary judgment on the basis that the plaintiff had not submitted adequate proof of a disability. The plaintiff then appealed this decision to the First Circuit.
On appeal, the court agreed with the plaintiff’s assertion that disabled status under the ADA does not require medical evidence of the extent of the injury. In some circumstances, such information would be necessary to establish the existence of a qualifying medical condition. But in others, a lay jury can determine this status without detailed medical evidence. Under ADAAA, the threshold for claiming disability was reduced to the point where juries can decide these issues without expert testimony or evidence.
Even though the plaintiff prevailed on this point, the First Circuit still affirmed summary judgment for the employer. The court concluded that even if the plaintiff met the disability definition, he did not submit sufficient proof of substantial impairment of a major life activity. While most plaintiffs readily can meet the disability and significant impairment thresholds, employers should carefully review these requirements as part of their analysis of whether the employee is entitled to ADA accommodations and other legal protections.
