12-06-2018
A police sergeant who sustained a knee injury while working could not establish that it “substantially limited” one or more major life activities.Mark Mancini was treated medically for his knee injury and was out of work for approximately six months. The City of Providence would not allow him to return to work on light duty. Meanwhile, he applied for a promotion which he did not receive. He believed had been discriminated against based on his disability and sued for violation of the Americans with Disabilities Act (ADA).
Mr. Mancini’s case was dismissed by the district court because the court found he had not established that he was disabled within the meaning of the ADA. In reviewing the case, the First Circuit Court of Appeals noted that a lack of medical evidence for a physical impairment did not necessarily end a disability case. The need for such evidence would depend on the circumstances of each case. In this matter, Mr. Mancini referred to his “knee injury” which a lay jury could understand. However, there was insufficient evidence on the record that the knee injury “substantially limited” one or more major life activities. He alleged that his “knee injury substantially limited his ability to stand, walk [and] bend…such that he could not perform the essential functions of [his] position.” However, Mr. Mancini failed to provide more than conclusory statements and needed to supply further details as to how the limitations manifested themselves to meet the standard.