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Carl Summers v. Altarum Institute, Corporation

Court of Appeals for the Fourth Circuit
2014 WL 243425, 740 F.3d. 325 (2014)
ELI5:

Rule of Law:

A physical impairment does not need to be permanent or long-term to be considered a 'disability' under the Americans with Disabilities Act Amendments Act of 2008 (ADAAA); a temporary impairment can qualify if it is sufficiently severe.


Facts:

  • In July 2011, Carl Summers began working as a senior analyst for Altarum Institute, a role which required him to work on-site at a client's office.
  • On October 17, 2011, Summers fell while exiting a commuter train, sustaining serious injuries including a fractured left leg, torn meniscus, fractured right ankle, and a ruptured quadriceps tendon in his right leg.
  • Following multiple surgeries, doctors forbade Summers from putting any weight on his left leg for six weeks and estimated he would be unable to walk normally for at least seven months.
  • While hospitalized, Summers contacted Altarum to discuss working from home as an accommodation during his recovery, proposing a gradual return-to-work plan.
  • Altarum granted Summers short-term disability benefits but did not engage in any interactive process regarding his request for accommodation.
  • On November 30, 2011, Altarum informed Summers that his employment was being terminated effective December 1, 2011, so the company could place another analyst in his role.

Procedural Posture:

  • Carl Summers filed a complaint in the U.S. District Court for the Eastern District of Virginia, alleging wrongful discharge and failure to accommodate under the ADA.
  • The district court granted Altarum's motion to dismiss the complaint without prejudice.
  • Summers then filed a new lawsuit presenting the same claims.
  • The district court again granted Altarum's motion to dismiss, this time with prejudice, on the grounds that Summers's temporary condition was not a disability.
  • Summers, as appellant, appealed the dismissal of only the wrongful-discharge claim to the U.S. Court of Appeals for the Fourth Circuit, where Altarum was the appellee.

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Issue:

Does a severe temporary physical impairment that substantially limits a major life activity for several months constitute a 'disability' under the Americans with Disabilities Act, as amended by the ADAAA of 2008?


Opinions:

Majority - Motz

Yes. A sufficiently severe temporary impairment can constitute a disability under the ADA as amended by the ADAAA. The district court erred by relying on pre-ADAAA precedent, such as Toyota v. Williams, which Congress expressly abrogated with the 2008 amendments. The ADAAA was enacted to broaden the scope of protection and mandates that 'disability' be construed broadly. Pursuant to delegated authority, the EEOC promulgated regulations clarifying that an impairment lasting even fewer than six months can be 'substantially limiting' if it is 'sufficiently severe.' Summers's inability to walk for an estimated seven months is a severe impairment that plausibly falls within the ADAAA's expanded definition. The district court also erred by reasoning that Summers was not disabled because he could have worked with a wheelchair; the ADAAA requires that the determination of disability be made without regard to mitigating measures or reasonable accommodations.



Analysis:

This case is significant as one of the first appellate court decisions to interpret the expanded definition of 'disability' under the ADAAA. The ruling firmly establishes within the Fourth Circuit that severe, temporary impairments are not categorically excluded from ADA protection, breaking from a more restrictive line of pre-amendment cases. This decision broadens the scope of employees who can seek protection under the ADA and reinforces the employer's duty to engage in an interactive process even for non-permanent conditions. It signals to lower courts and employers that the focus should be on the severity of the limitation on a major life activity, not merely its duration.

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