Case name: Weigand v. Niagara Frontier Transportation Authority, et al., No. 03-CV-794S (W.D. N.Y. 02/16/10).
Ruling: The U.S. District Court, Western District of New York granted summary judgment to the employer in a mechanic's Americans with Disabilities Act and Rehabilitation Act suit. The court remanded the employee's state law suit to state court because no federal question remained.
What it means: A simple lifting restriction that prevents an employee from performing some of his duties but does not preclude him from working a broad range of jobs does not create a disability under the ADA or Rehabilitation Act. Physical or mental conditions must substantially limit a major life activity, not just slightly restrict an employee.
A bus mechanic injured his neck on the job. After taking workers' compensation leave and being given a 50-pound lifting restriction, he was allowed to return to work on light duty. While on light duty, the mechanic complained that he was denied overtime opportunities, work assignments, a shift change, and other benefits that were given to noninjured employees. He recovered sufficiently for his restriction to be removed and returned to his regular job. However, he sued for discrimination under the ADA and state law.
The District Court granted summary judgment to the employer on the federal claims. The court determined that the mechanic was not disabled under the ADA and Rehabilitation Act. He was not substantially limited in the major life activity of working because he was able to perform most of the essential functions of his job, the court said, and he continued working during the relevant period. The court added that, at most, the mechanic was only restricted from being able to perform jobs entailing heavy lifting. However, this restriction was not broad enough to create a disability.
The mechanic argued that he qualified as disabled under New York's state disability discrimination law. However, the court pointed out that the state law had a less restrictive standard for determining eligibility. The court also rejected the mechanic's reliance on his medical documentation, as simple diagnoses without proof of substantial limitations do not qualify under federal statutes.
The court declined to exercise jurisdiction over the mechanic's state law claims since no federal issues remained.
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March 29, 2010
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