Work-Related Stress Not a Disability

By Joseph Hunt

It is a common scenario: An employee claims a particular supervisor causes too much stress, exacerbating a medical condition, and the employee requests reassignment as an accommodation. Must the employee be reassigned as a reasonable accommodation under the ADA?

“Not so fast,” says the Second Circuit Court of Appeals. In Woolf v. Strada, 19-860-cv (2d Cir. Feb. 6, 2020), the court held that before considering whether reassignment is warranted, the employee must first establish he is “disabled” within the meaning of the ADA, e.g. that he has a substantial limitation to a major life activity. Because the employee in this case could have done the same job he had been doing if he were managed by a different supervisor, he could not prove he had a substantial limitation in the major life activity of working. The employee’s work-induced impairment did not limit his ability to work in a class or broad range of jobs. Therefore, the employee was not “disabled” and was not entitled to a reasonable accommodation.

The Woolf decision is a useful reminder that if an employee can do the job with a different supervisor, the employee is not “disabled” within the meaning of the ADA.