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Regarding Employee as “Paranoid” and “Irrational” Not Enough To Satisfy ADA (at least pre-ADAAA)

Posted in Discrimination & Harassment, Litigation

You’ve seen a lot on this blog about how the ADA Amendments Act (ADAAA) may have a significant impact on how employment discrimination cases proceed.

We haven’t had many cases yet to judge that on because the Act was not retroactive, but a case recently decided in Connecticut District Court gives us some insight into how courts may view such claims.

In Eaddy v. City of Bridgeport (download here), a former probationary police officer claimed that her employment was terminated for lack of fitness for duty.  She claimed — under the old version of the ADA — that her employer "regarded" her as disabled because the police chief allegedly described her behavior as "irrational, irate, and uncooperative as well as paranoid". 

The District Court disagreed.  Because the termination occurred in July 2008, it used the the pre-ADAAA standard.  That standard, said the court, states that in order to prevail, the plaintiff must show that her employer regarded her as "having an impairment that would be significantly limiting to the average person in the population". 

The Court, having looked at the statement, said that there was no indication that the chief was using the terms "irrational" and "paranoid" in a clinical sense.  Any reasonable jury, he suggests that the reference is not "a suggestion that Ms. Eaddy suffers from paranoid delusions in the psychiatric sense, but rather that she is irrationally distrustful of her peers and the police department.". 

The Court teases that the standard has changed.   And indeed, looking at the ADAAA itself, it is not difficult to see that the analysis may very well have been different.

Pursuant to the ADAAA, an employee is now “regarded as” disabled—and thus entitled to protection from discrimination—if the employer believes the employee has any physical or mental impairment, regardless of whether the employer believes the impairment limits a major life activity at all.

Would that have changed the outcome here? We’ll never know but I suspect we’ll quickly find out as cases mature. 

Of course, even with this change, employers should not assume the employee is automatically entitled to a victory either; the employee must still show underlying discrimination. But it does overcome a major issue that had stood in the way as the Eaddy case demonstrates.

  • http://www.mesrianilaw.com/ Mesrianilaw

    Good decision, while I do think that the ADAAA’s expanded protections are important for all disabled employees and applicants for their protection and equal employment opportunity, using the ADAAA as a defense for the termination an employee who is “irrational, irate, and uncooperative as well as paranoid” is too far-fetched. Yes, employees have the right to be protected against discrimination but employers should not be persecuted for making business decisions that have nothing to do with disability discrimination.