02-25-2026
A North Carolina federal court held that the ADA protects women who have significant symptoms caused by endometriosis1. The case was recently settled for six figures after a federal judge denied the employer’s motion for summary judgment.
Christian Worley began experiencing very painful menstrual pain when she was just 12 years old. By the time she entered college, Worley missed classes due to intense pain. Post-graduation, Worley worked for the North Carolina Department of Public Safety (NCDPS) as a Juvenile Court Counselor Trainee. While employed there, she began undergoing fertility treatments, which caused her symptoms to worsen. Worley asked to take the first day of her menstrual cycle off from work each month because of the pain. The manager responded that if he gave Worley that time off, he would have to do the same for every female employee. This manager told her that she was taking too much sick time and that it demonstrated a “poor work ethic.” He refused to grant any accommodation of her symptoms and advised her that further discussions would lead to “disciplinary action up to and including termination.” Worley resigned from the position.
Worley represented herself and sued NCDPS, alleging failure to provide reasonable accommodation for her endometriosis symptoms in violation of the ADA. She consulted several lawyers, who cautioned her that the case would be difficult to win. The judge noted that endometriosis may not necessarily be recognized as a disability under the ADA. However, severe symptoms can qualify as a disability, as was the case with Worley.
1 Endometriosis is an inflammatory disease affecting the uterus and impacts 1 in 10 American women. Symptoms may include chronic pain, pelvic floor dysfunction, poor bladder health, lower back pain, pain with sex, and sometimes infertility. (USA Today)