Case name: Webb-Eaton v. Wayne County Community College District, No. 12-14821 (E.D. Mich. 07/24/13).
Ruling: The U.S. District Court, Eastern District of Michigan dismissed the plaintiff’s discrimination claim under the Americans with Disabilities Act.
What it means: Although learning qualifies as a major life activity under the ADA, learning a specific career is not covered by the statute.
Summary: Tenita Webb-Eaton suffered from a latex allergy that interfered with her ability to participate fully in the Wayne County Community College District’s nursing curriculum. After a series of incidents where she was exposed to latex and had severe allergic reactions, she filed suit in federal court. Webb-Eaton alleged that WCCCD violated her rights under the ADA by failing to accommodate her latex allergy.
The ADA defines “disability” as “a physical or mental impairment that substantially limits one or more major life activities of such individual.” Accordingly, to conclude that a person is disabled, a court must find that (1) there is a physical impairment, (2) which affects a major life activity identified by the plaintiff, and (3) substantially limits that life activity.
The college sought dismissal of the claim on the grounds that Webb-Eaton’s latex allergy did not substantially limit learning within the meaning of the ADA.
The Court agreed with the college. The judge ruled that although learning was a major life activity, the inability to pursue a particular course of study did not amount to a substantial limitation of the major life activity of learning. The court dismissed Webb-Eaton’s claim.