No ADA Protection for Employee Whose Condition Was Triggered by Supervisor’s Management Style

Many employers struggle with employees who seek the accommodation of a new supervisor, alleging that their disability is caused or triggered by a particular supervisor. The U.S. Court of Appeals for the Sixth Circuit found, however, that an employee whose medical condition was triggered by a specific supervisor was not, in fact, disabled within the meaning of the Americans with Disabilities Act.

In Tinsley v. Caterpillar Financial Services Corp., the employee suffered from PTSD. Following a series of complaints about her supervisor, the employee requested a transfer to a different supervisor as an accommodation for her condition, as well as leave. Both were denied, she retired, and then sued, asserting claims under the ADA and Family and Medical Leave Act.

The Sixth Circuit noted that the ADA defines a disability as a substantial limitation on a major life activity – in this case, working. In this case, the employee failed to show that she was substantially limited in working, as she was not limited in her ability to perform “a class of jobs or broad range of jobs in various classes.” The inability to perform the unique aspects of a single job, as alleged here, does not meet that standard. Accordingly, the Sixth Circuit found that the employee was not disabled within the meaning of the ADA.