Michael Booth v. Nissan N. Am., Inc.
927 F.3d 387 (2019)
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Rule of Law:
Under the Americans with Disabilities Act (ADA), an employee's inability to perform a single, specific job due to a physical impairment does not render them 'disabled' if they are not substantially limited in the major life activity of working, which requires being precluded from a class or broad range of jobs.
Facts:
- Michael Booth began working on an assembly line at a Nissan factory.
- In 2004, Booth injured his neck, and a physician issued permanent work restrictions limiting overhead work and neck flexion.
- For approximately ten years following the injury, Booth continued to work on the assembly line within his restrictions without incident.
- In the fall of 2015, Booth requested a transfer to a 'material handling' position.
- In November 2015, Nissan denied the transfer request, stating that Booth's work restrictions conflicted with the requirements of the material handling role.
- Around the same time, Nissan restructured the assembly line, requiring workers to perform four jobs instead of two, and Booth informed management that two of the new jobs would violate his restrictions.
- Nissan supervisors suggested Booth get his medical restrictions re-evaluated, with one manager warning that Nissan would not have a job for him unless the restrictions were changed.
- Booth's physician subsequently modified his work restrictions, which Booth agreed with, and Nissan determined he could perform the new four-job role.
Procedural Posture:
- In November 2016, Michael Booth filed an intake questionnaire with the Equal Employment Opportunity Commission (EEOC).
- In December 2016, Booth filed a formal charge with the Tennessee Human Rights Commission alleging disability discrimination.
- The EEOC dismissed Booth's charge, concluding there was insufficient information to establish an ADA violation.
- Booth filed a lawsuit against Nissan in the U.S. District Court for the Middle District of Tennessee, alleging disability discrimination and failure-to-accommodate under the ADA.
- Nissan filed a motion for summary judgment on all claims.
- The district court (trial court) granted Nissan's motion for summary judgment.
- Booth (appellant) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Sixth Circuit, with Nissan as the appellee.
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Issue:
Does an employee with medical work restrictions qualify as 'disabled' under the Americans with Disabilities Act (ADA) when those restrictions only prevent him from performing a single, specific job he requested, but do not substantially limit his ability to perform his current job or a class or broad range of jobs?
Opinions:
Majority - Nalbandian, Circuit Judge.
No. An employee with medical work restrictions is not 'disabled' under the ADA if those restrictions only prevent performance of a single job. The court reasoned that even after the ADA's 2008 amendments, which broadened the definition of disability, a plaintiff claiming a substantial limitation in the major life activity of 'working' must still demonstrate an inability to perform a class of jobs or a broad range of jobs. Booth failed to make this showing because his restrictions only prevented him from taking the material handling position, while he successfully worked on the assembly line for over a decade. The evidence did not show that Nissan regarded him as disabled from a class of jobs, only from one specific role. The court also held that Booth's failure-to-accommodate claim fails because he did not prove he was disabled, and furthermore, Nissan did accommodate him by keeping him in his two-job position while he sought medical re-evaluation.
Analysis:
This decision reaffirms that the standard for proving a disability based on the major life activity of 'working' remains significantly high, even after the ADA Amendments Act of 2008. The court's holding clarifies that the pre-amendment precedent requiring a plaintiff to show preclusion from a 'class or broad range of jobs' is still controlling. This makes it challenging for employees to bring successful ADA claims based on a denied transfer or promotion if they can still perform their existing job or other similar jobs. The case solidifies the distinction between an impairment that interferes with a particular job and one that substantially limits the general life activity of working.
