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Stress-Induced Migraines Not Protected by ADA

The Second Circuit Court of Appeals has held that an employee suffering from migraines triggered by his particular position did not have an Americans with Disabilities Act (ADA) qualifying disability.
Shortly after beginning his employment at Bloomberg LP, Ronald Woolf “suffered from migraines that left him temporarily incapacitated, which impaired his work ability and his life activities more generally.” He developed these migraines because of stress at work, and they worsened as he received negative performance reviews. According to those reviews, he struggled in his ability to collaborate with important business managers, had poor problem-solving skills, limited knowledge of the product, and low internal credibility. Woolf tried to transfer to a different position, but he was told that he had to be in good standing to transfer. His migraines continued to worsen. He notified Bloomberg’s human resources that he had serious migraines. Woolf provided a doctor’s note outlining the severe consequences, such as heart attack or stroke, that could result because of his stress-induced migraines. Bloomberg granted Woolf’s requests for intermittent medical leave. However, after another poor performance review, Woolf was fired.
Upon appeal of the dismissal of his claims, the Second Circuit reviewed only the question of whether the migraines substantially limited Woolf’s ability to work, essential to qualifying as a disability under the ADA. The parties agreed that his migraine condition would be considered a “physical or mental impairment” under the ADA. While the migraines did impact his performance at work, Woolf reported that the stress was caused by working for his direct supervisors. Woolf believed that if he had been managed by different supervisors, he would have been able to perform his position. Under Second Circuit precedent, “where a plaintiff’s condition leaves him unable to perform only a single, specific job, ‘he failed to establish a substantial impairment to his major life activity of working.’” Other federal courts reviewing this issue have reached the same conclusion including the First, Sixth, Seventh, Tenth, and D.C. Circuits. Because Woolf did not attempt to show that his migraines limited his ability to work in a class or broad range of jobs, he was not “disabled” within the meaning of the ADA.