Matthew Weaving v. City of Hillsboro
763 F.3d 1106 (2014)
Rule of Law:
Under the Americans with Disabilities Act (ADA), an impairment substantially limits the major life activity of 'interacting with others' only when it results in severe problems such as consistently high levels of hostility, social withdrawal, or a failure to communicate at a basic level, not merely causing an individual to be cantankerous or have trouble getting along with coworkers.
Facts:
- Matthew Weaving was diagnosed with 'hyperkinetic activity' (now known as ADHD) as a child and took medication until age twelve, believing he had outgrown the condition.
- While working as a police officer for the Beaverton Police Department, Weaving was described in evaluations as 'abrasive' and 'intimidating,' and was removed from an interagency team due to 'personality conflicts.'
- Weaving was hired by the Hillsboro Police Department (HPD) in 2006, and after being promoted to sergeant in 2007, his interpersonal difficulties escalated.
- He sent a hostile and metaphorical email to a fellow sergeant, telling him to stay in the 'shallow end' of the pool and 'bring your water wings' to find Weaving in the 'deep end.'
- Weaving also referred to some HPD officers in a derogatory manner as 'salad eaters' to imply they were weak and criticized the language skills of a newly hired Latino officer.
- In March 2009, a subordinate officer filed a grievance against Weaving with the City Human Resources Department after receiving what he felt was a disproportionately harsh disciplinary letter.
- While on administrative leave pending an investigation into the grievance, Weaving met with a psychologist who diagnosed him with adult ADHD.
- Weaving informed HPD of his diagnosis and requested reinstatement as a reasonable accommodation, but the City terminated his employment after its internal investigation concluded he had created a hostile work environment.
Procedural Posture:
- Matthew Weaving sued the City of Hillsboro in federal district court, alleging discrimination in violation of the Americans with Disabilities Act.
- The case was tried before a jury, which returned a verdict in favor of Weaving.
- The district court entered judgment for Weaving, awarding damages, back pay, front pay, and attorney's fees.
- The City of Hillsboro filed a renewed motion for judgment as a matter of law and a motion for a new trial, both of which the district court denied.
- The City of Hillsboro (appellant) appealed the district court's denial of its post-trial motions to the U.S. Court of Appeals for the Ninth Circuit; Weaving is the appellee.
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Issue:
Does an employee's ADHD, which causes recurring interpersonal problems with coworkers such as abrasiveness and hostility, constitute a disability under the Americans with Disabilities Act by substantially limiting the major life activities of 'working' or 'interacting with others'?
Opinions:
Majority - W. Fletcher
No. An employee's ADHD that causes interpersonal problems in the workplace does not rise to the level of a disability under the ADA, as it does not substantially limit the major life activities of working or interacting with others. Regarding the ability to work, the evidence showed Weaving was a competent and skilled police officer who earned promotions, indicating his ADHD did not prevent him from performing his job compared to the general population. Regarding the ability to interact with others, the court distinguished between merely having 'trouble getting along with coworkers' and a substantial limitation on the fundamental ability to interact. Citing its precedent in McAlindin, the court held that a plaintiff must show severe problems like social withdrawal or a total inability to communicate, which Weaving did not demonstrate. His problems were context-specific and amounted to being 'cantankerous,' which is insufficient to qualify as a disability under the ADA.
Dissenting - Callahan
Yes. A reasonable jury could, and did, find that Weaving's ADHD substantially limited his major life activity of interacting with others, and the majority improperly usurps the jury's role by reweighing the evidence. The majority misapplies the circuit's precedent in McAlindin, which requires only 'severe problems' on a 'regular basis'—a standard Weaving met with evidence of career-long, medically diagnosed communication failures. The majority wrongly narrows this standard to only include those who are 'housebound,' while ignoring substantial medical testimony that Weaving's behavior was a symptom of his disability, not just a character flaw. The jury was entitled to believe this evidence and its verdict should be respected, as the law protects the disabled, not just the likeable.
Analysis:
This decision significantly clarifies and narrows the standard for what constitutes a substantial limitation on the major life activity of 'interacting with others' under the ADA within the Ninth Circuit. It establishes a high threshold, requiring an impairment so severe that it prevents basic social functioning, distinguishing it from poor interpersonal skills or workplace friction, even when linked to a diagnosed condition like ADHD. The ruling provides employers with greater protection against ADA liability when terminating employees who create hostile work environments. Consequently, it makes it more difficult for plaintiffs with mental or psychological impairments that manifest as behavioral issues to succeed on an ADA claim based on this major life activity.
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