FOURTH CIRCUIT RULES THAT THE ABILITY TO INTERACT WITH OTHERS IS A MAJOR LIFE ACTIVITY UNDER THE ADA

In the case of Jacobs v. N.C. Administrative Office of the Courts, No. 13-2212, the Fourth Circuit Court of Appeals held that social anxiety disorder may be a disability under the Americans with Disabilities Act Amendments Act (“ADAAA”). In that case, plaintiff Christina Jacobs worked as a deputy clerk at a courthouse in North Carolina. She was later promoted to position at the front counter that required customer service and public interaction. Jacobs, however, suffered from social anxiety disorder from childhood. After she began her new job, she began to experience extreme stress, nervousness and panic attacks, and became paralyzed when she was asked a question that she did not immediately know the answer to. As a result, Jacobs asked her supervisor for an accommodation, that is, to be assigned a role that would require less direct public interface. Her request for an accommodation was not acted on, and just a few short weeks later, she was terminated. Jacobs filed a lawsuit alleging disability discrimination under the ADAAA. The district court granted summary judgment in favor of the defendant, and Jacobs appealed.

The Fourth Circuit reversed the lower court’s decision and held that the district court ignored facts that could have supported a jury verdict in Jacobs’ favor. Specifically, the Fourth Circuit ruled that an individual’s ability to interact with others is a major life activity and that a jury could conclude that Jacobs was substantially limited in her ability to interact with others, and thus, disabled under the ADAAA.

Prior to the amendment of the Americans with Disabilities Act, federal courts frequently would summarily dismiss claims under the Act because plaintiffs were not sufficiently impaired under the law. However, in response to these dismissals, Congress amended the Americans with Disabilities Act in 2008 and substantially broadened the definition of a disability. Now, most significant diagnosed medical conditions will qualify as disabilities.

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