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Work Restrictions Are Not Enough to Qualify for ADA

The Sixth Circuit Court of Appeals has reiterated that employees must show they are not able to work in a “class or broad range of jobs” to establish that they are disabled within the meaning of the Americans with Disabilities Act (ADA).
Michael Booth worked as an assembly line worker for Nissan North America, Inc. After injuring his neck on the job, Booth had permanent work restrictions. He was not supposed to perform work that was above his shoulders more than a third of the time, and he was not able to flex or extend his neck more than 66% of the time. He attempted to transfer to another position and also requested accommodations. Nissan denied his requests; Booth sued under the ADA.
In addition to a timeliness issue, the Sixth Circuit Court of Appeals determined that Booth had not shown that he was disabled within the meaning of the ADA. According to the court, Booth relied solely on the fact that he had work restrictions and the denial by Nissan to transfer him because of those restrictions, to establish that he was disabled under the ADA. However, the court noted it was not enough. “[A] plaintiff who alleges a work-related disability ‘is still required to show that her impairment limits her ability to perform a class of jobs or broad range of jobs.’” The inability to perform a particular function at work is not the same as being “substantially limited” in the major life activity of “working.” In this instance, Booth had been able to work on the assembly line even after injuring his neck for an extended period of time. His claim therefore failed.