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ADA Claim Requires Limit of Ability to Perform Broad Range of Jobs

Cynthia Tinsley worked for Caterpillar Financial Services for 19 years. She was diagnosed with post-traumatic stress disorder (PTSD) well into her employment for Caterpillar. In 2015, Tinsley took a leave under the Family and Medical Leave Act (FMLA). When she returned to work, some of her assignments were distributed to others and Caterpillar made other attempts to reduce her stress. Her work did not improve and she was placed on a performance improvement plan. During this meeting, she complained about some actions of her co-workers; Tinsley claimed that her supervisor changed towards her after those complaints. Tinsley went out on another leave and when she was ready to return, her doctor wrote a note that “strongly recommended her working in a different work environment and specifically under a different manager.” Caterpillar denied Tinsley’s request for a different manager, finding it was not a reasonable accommodation. She did not return to work.
The district court dismissed her case on summary judgment. In reviewing her claim for violation of the Americans with Disabilities Act, the Sixth Circuit Court of Appeals looked at her representation that she could not perform her job because of her supervisor’s management style which purportedly “triggered” her disability. Relying on court precedent and EEOC guidelines, the Sixth Circuit held that Tinsley was not eligible for relief because she did not prove that she was substantially limited “in either a class of jobs or a broad range of jobs in various classes” and thus was not disabled under the statute.
Tinsley was able to proceed on her FMLA retaliation claim as she received a negative performance review just two months after taking FMLA leave. Caterpillar must set forth a legitimate non-discriminatory reason for its adverse employment actions.