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Permanent work restrictions do not equate with “disability” under the ADA:

Wednesday, July 1, 2020

Booth v. Nissan North America, Inc., 927 F. 3d 387 (6th Cir.)

Employee had permanent work restrictions from a neck injury. He worked with permanent restrictions on the assembly line at Nissan for a decade without incident. He requested transfer to a different position in the facility which the employer denied because the requested position’s duties conflicted with the employee’s permanent restrictions. Soon thereafter, the employer announced plans to restructure the assembly line to include additional job duties. The additional job duties would have conflicted with the employee’s restrictions. When the employer told the employer this, the employer suggested the employee see his physician to see if the restrictions could be modified. He continued working on the original assembly line within his restrictions, and saw his physician. His physician modified his restrictions, clearing him to work on the restructured assembly line.

The employee brought suit in Federal Court alleging the employer violated the ADA by discriminating against him due to his disability by denying his transfer request and by failing to accommodate him by pressuring him to remove his work restrictions.

The Sixth Circuit Court of Appeals affirmed summary judgment to Nissan, holding that there was no evidence the employee was disabled or that the employer failed to accommodate him.  The Court explained that, having work restrictions does not equate with disability under the ADA. There must be a showing that the condition precludes the employee from working in a class or broad range of jobs.   

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