Background
Timothy Capers worked as a store manager for Walmart from two thousand and six until his termination in two thousand and nineteen. After suffering a mild stroke in two thousand and eighteen, Capers experienced symptoms including slower speech and muscle weakness but continued to work without requesting medical leave. He later requested a transfer due to health issues but was terminated shortly thereafter. Capers sued Walmart under the Americans with Disabilities Act, alleging disability discrimination and failure to accommodate. The district court granted summary judgment for Walmart, finding Capers was not disabled under the Act. Capers’s wife, Nicole Ester-Capers, substituted as plaintiff after his death and appealed the decision.
The court’s reasoning
The Fifth Circuit reviewed the summary judgment de novo and applied the McDonnell Douglas burden-shifting framework. The court affirmed that the district court correctly found Capers failed to establish a prima facie case because he did not qualify as disabled. The court rejected the argument that the ADAAA created a regulatory presumption of disability for stroke or diabetes. It noted that Capers continued to perform his routine duties, never sought medical leave, and subsequently obtained employment requiring more physical labor. The court concluded there was no evidence that his residual symptoms substantially limited a major life activity such as caring for oneself or performing manual tasks.
What it means going forward
Employers and courts must still require specific evidence that an impairment substantially limits a major life activity to establish disability status under the ADA, even when the ADAAA applies. Employees who continue working without accommodations or who secure physically demanding jobs may find it difficult to prove they are disabled under the statute.