a. How many employees must an employer have before the American with Disabilities Act (ADA) prohibits discrimination on the basis of disability?
b. What is the definition of a disabled person under the American with Disabilities Act (ADA)?
c. What did Ms. Allen need to show in order to establish that her migraines interfered with her ability to work?
After some years as a medical assistant at South Crest Hospital, Alethia Allen requested a transfer to work for a different physician in the same hospital. Unfortunately, Allen found her new job to be much more stressful than the old one. Indeed, it was so stressful that she began suffering severe migraine headaches several times a week. Prior to this new job, she had only had one migraine headache in her life.
Ultimately, Allen resigned because of the migraines. The hospital asked that she stay on to cover for some assistants who were on vacation. Allen agreed to do so and then decided she did not want to quit after all. But before the hospital made a decision about whether she could stay, she left work one day to seek treatment for a migraine at the emergency room. That night, the doctors in her practice decided she could not continue in her job. After leaving South Crest, her migraines stopped.
Allen filed suit against South Crest for violating the ADA. During discovery, she testified that on most days, she could care for herself and go to work, but that on days on which she took the migraine medication, she would come home from work and immediately "crash and burn." In other words, she could not care for herself but instead would go straight to bed.
The trial court granted South Crest's motion for summary judgment. Allen appealed.