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Job-Related Anxiety and the ADA


Employees are protected from discrimination at the hands of their employers, based on certain disabilities. The ADA, or the Americans with Disabilities Act, prohibits employers from making employment decisions based on an employee's protected medical condition. A major factor to be considered in applying the ADA is whether the medical condition at issue is actually protected by the statute. A common question asked by clients is whether job-related stress or anxiety is covered by the ADA. As with the majority of medical conditions, it depends on a variety of factors.

What constitutes a disability under the ADA?

The ADA protects an individual with a "disability." The term disability is loosely defined as "a physical or mental impairment that substantially limits one or more major life activities." So, where does job-related stress or anxiety fall in that definition?

Is job-related stress considered a disability under the ADA?

A recent decision from the Seventh Circuit Court of Appeals addressed the specific issue of whether job-related stress can be considered a disability under the ADA. In Carothers v. Cook County, the employee worked as a corrections officer for the Cook County Juvenile Detention Center. She had an altercation with a juvenile detainee in June 2009, as a result of which she developed an anxiety disorder. Carothers alleged in her discrimination complaint that she was terminated because of this medical condition. The legal issue was whether her job-related anxiety disorder constituted a disability under the ADA.

Does the condition affect a "major life activity?"

In Carothers' case, she claimed that her anxiety interfered with the major life activity of working. While the ADA considers working a "major life activity," there is a catch. The employee must be able to demonstrate more than a limitation in performing the specific functions of a single, specific job.

Instead, the employee must be able to show that her disability "significantly restricted her ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities." In Carothers' situation, the evidence only showed that her anxiety substantially limited her ability to interact with juvenile detainees in her job as a corrections officer.

Cases where a disability substantially limits the ability to work

Even if it can be shown that a job-related stress disorder substantially limits the ability to work, the employee must be able to perform the essential functions of her job, with or without reasonable accommodation. So, the question becomes, what possible reasonable accommodations would allow an employee with job-related stress to perform the essential functions of the job? If the stress disorder limits the ability to perform one specific job, then the disorder does not qualify as an ADA disability. On the other hand, if the stress limits the employee's ability to work generally, there may not be a reasonable accommodation available.

If you feel you have been the victim of disability discrimination, or if you have any questions regarding your employment rights, please contact the experienced employment attorneys at Michel | King , either online or by calling us at (205) 265-1880.

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