Allen v. Southcrest Hospital

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In Brief

The 10th Circuit held that specific evidence is needed to show that a person’s disability—in this case, migraine headaches—substantially limits the person from the major life activity of “taking care of themselves.”

What Happened in Court

The 10th Circuit determined that an employee who suffered from migraines did not show that she was substantially limited in the major life activity of caring for herself without more specific evidence of how her migraine medication impacted her activities after work. Specifically, the Court suggested the need for more evidence on how early her medication caused her to go to sleep after work, and what normal activities she would do to take care of herself that she was unable to do. The court also reinforced the pre-ADAAA analysis that to be substantially limited in the major life activity of “working,” an employee’s disability must prevent her from working in a “class of jobs.”