Stress-Related Migraines Were Not a “Disability” Under the ADA, Court Holds

In Woolf v. Bloomberg L.P., 16-cv-6953 (PKC), 2019 WL 1046656 (S.D.N.Y. Mar. 5, 2019), the court, inter alia, granted defendant’s motion for summary judgment dismissing plaintiff’s claim of disability discrimination under the Americans with Disabilities Act (ADA).

In this case, Plaintiff alleges (inter alia) that his employer violated the ADA by terminating him on the basis of, and failing to accommodate, his “disability” (here, stress-induced migraines).

The court finds that plaintiff’s condition was not a “disability”, as defined by the statute. This decision is instructive as to what impairments/medical conditions qualify – and do not qualify – as ADA “disabilities.”

Initially, the court summarized the statutory definition:

A “disability” under the ADA includes “a physical or mental impairment that substantially limits one or more major life activities….” 42 U.S.C. § 12102(1)(A). The definition is “construed in favor of broad coverage….” Id. § 12102(4)(A). “Not every impairment is a ‘disability’ within the meaning of the ADA; rather, there are two requirements: the impairment must limit a major life activity and the limitation must be substantial.” Capobianco v. City of New York, 422 F.3d 47, 56 (2d Cir. 2005). Major life activities include core physical functions like walking and breathing, and other common activities such as reading and working. 42 U.S.C. § 12102(2)(A); see also 29 C.F.R. § 1630.2(i). “An impairment is a disability … if it substantially limits the ability of an individual to perform a major life activity as compared to most people in the general population.” 29 C.F.R. § 1630.2(j)(ii). “[T]he determination of the existence of a substantial limitation on a major life activity must be determined on a case-by-case basis.”

As specifically relevant to this case, the court explained that “[p]eriodic migraine headaches do not amount to a disability under the ADA unless the plaintiff demonstrates that they result in a substantial limitation to a major life activity.”

The court assumed that plaintiff’s complex migraines were a “physical or mental impairment” under the ADA, but concluded that “[a]lthough Woolf has demonstrated that he is generally susceptible to stress-induced migraine headaches, his admission that he would be able to perform the same job functions if he were transferred to a different supervisor undermines his claim that he has a condition that substantially limits one or more major life activities.”