The Americans with Disabilities Act and related federal laws define disability broadly, but recent federal court decisions demonstrate the statute’s limits.

The ADA, as amended, defines disability to include any physical or mental impairment that substantially limits one or more major life activities. It is inclusive of employees who either have a record of such an impairment or are regarded as having a disability. Federal regulators have said that the law’s definition is intended to be construed broadly, though courts have at times declined to view certain conditions as covered.

In Peddada, the court examined a list of major life activities and whether the plaintiff’s burnout substantially limited any one of them. The list included sleeping, thinking, concentrating and communicating, each of which the plaintiff cited in his complaint. In doing so, the judge relied on testimony from the plaintiff’s expert witness as well as another physician’s clinical evaluation.

The court noted that the plaintiff’s witness did not conclude that his burnout affected his sleep. On the other three activities, the judge cited the clinical evaluation of the plaintiff, which determined that neither thinking, concentrating nor communicating had been impaired.

To the extent that the plaintiff and his expert witness believed these three functions were impaired, “both implicitly concede that these functions were only impaired as to the performance of his specific job of being a radiation oncologist,” the court said. The plaintiff could not show that his burnout affected his life activities outside of when he performed his duties, and he did not assert that his major life activity of working was substantially impaired.

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