Do Migraines Qualify as a "Disability" Under the ADA?

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When it comes to disability discrimination, it is important to understand that not every physical or mental limitation a person may have actually qualifies as a “disability” under the Americans with Disabilities Act (ADA) or other civil rights laws. The ADA actually defines a disability as an impairment “that substantially limits one or more major life activities.” While courts are supposed to interpret this definition broadly, the mere fact that a condition makes an employee's working life more difficult is not always enough to render it a disability.

Judge Rules Supervisor-Induced Stress Not Sufficient to Prove Disability

Consider this recent decision from a federal judge here in Manhattan, Woolf v. Bloomberg LP. The plaintiff worked as a sales representative for the defendant. At the start of his employment in 2011, the plaintiff represented to the defendant “that he had no disability and no history of impairments that limited his major life activities.”

But the plaintiff did have a history of “migraine and tension headaches” that predated his employment with the defendant. During his employment, the plaintiff alleged that these migraines “left him temporarily incapacitated” and “impaired his work ability and life activities more generally.”

To make a long story short, the plaintiff received increasingly negative performance reviews at work. The plaintiff maintained his supervisors “deliberately manufactured an unnecessary stress,” which triggered further migraine attacks and led to his decline in performance. Eventually, the defendant fired the plaintiff, and he responded by filing a discrimination complaint with the U.S. Equal Employment Opportunity Commission (EEOC).

The EEOC complaint eventually led to the plaintiff's present lawsuit in federal court. The judge concluded that no “reasonable jury” could find that the plaintiff's “stress-induced condition was a 'disability under the ADA,” and therefore granted summary judgment to the defendant.

As the judge explained, “Periodic migraine headaches do not amount to a disability under the ADA unless the plaintiff demonstrates that they result in a substantial limitation to a major life activity.” While work is a “major life activity,” the evidence presented by the plaintiff indicated that his problem was not so much the functions of his job, but rather his difficulty in working with his supervisors.

The plaintiff said that the defendant violated the ADA by refusing to reassign him to different supervisors who would not exacerbate his stress levels. The judge said this effectively proved the plaintiff was not disabled as a matter of law, since judges in similar cases have “repeatedly concluded that an ability to continue work under a different supervisor means that a plaintiff does not suffer a substantial impairment to the ability to work.”

Contact a New York City Disability Discrimination Lawyer Today

It is not always obvious when a physical or mental impairment crosses the line from inconvenience into a recognized disability under the ADA. An experienced New York City employment attorney can review the unique facts of your case and advise you appropriately. Contact the Nisar Law Group, P.C., to schedule an initial consultation with a member of our legal team today.

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