Work Restrictions Don’t Necessarily Amount to a Disability

The U.S. Court of Appeals for the Sixth Circuit held that the fact an employee had work restrictions that prevented his transfer did not mean that he was disabled under the Americans with Disabilities Act.

In Booth v. Nissan North America, Inc., an employee suffered an injury resulting in work restrictions, but those restrictions did not affect his ability to perform his job duties, which he continued to do for another decade. He then applied for a transfer, but those restrictions conflicted with the requirements of the new position and he was denied the transfer. In the meantime, his current job was restructured to add new duties that were also in conflict with his restrictions. The employee’s doctor then reevaluated him and modified the restrictions such that he could perform all the duties. He then sued, alleging violations of the ADA.

The Sixth Circuit found that the denial of transfer claim was untimely, as he failed to file a charge of discrimination with the Equal Employment Opportunity Commission within 300 days of the denial decision. Although the employee noted that the denial had been reiterated within that 300-day period, the Sixth Circuit found that the 300-day period ran from the date of the final decision, and not any date of subsequent re-explanation of the decision.

In addition, the Sixth Circuit also disposed of the discrimination claim. If an employee claims that he is substantially limited in the major life activity of working, he must show that his impairment limits his ability to “perform a class of jobs or broad range of jobs.” The Sixth Circuit held that “simply having a work restriction does not automatically render one disabled…nor does being unable to perform a discrete task or a specific job.”