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When Anxiety Does Not Qualify as a Disability

The Equal Employment Opportunity Commission (EEOC) sued West Meade Place (Meade) for firing Carma Kean in violation of the Americans with Disabilities Act. Kean was employed as a laundry technician at Meade’s health care center when she requested an accommodation for her anxiety disorder. She submitted a doctor’s note asserting that she was unable to work during “flareup/episodes” of her anxiety. Kean allegedly did not receive any accommodation and was terminated.
To establish a claim for disability discrimination, the EEOC had to show the federal district court that Kean had a physical or mental impairment which substantially limited one or more of her life activities. The proof of this disability was centered on the doctor’s note regarding Meade. During the doctor’s deposition, he could not provide any information to support his diagnosis. In his testimony, the doctor seemingly relied on Kean’s representation and her prior diagnosis of anxiety by another doctor to reach his conclusion. He did not provide any information to support a claim that her anxiety substantially limited any major life activity. Moreover, Kean herself could not identify any substantial limits on her activities caused by her anxiety.
The EEOC argued that Kean had provided a “record of impairment” to Meade at the start of her employment. However, the court did not find any information in her pre-employment forms to suggest that she had previously been treated for a mental condition, or that she had been treated for any such issues in the five years before her employment. The federal court dismissed the case because the EEOC had failed to demonstrate that she had a disability.