Fourth Circuit Interprets ADA Amendments Act of 2008

In Summers v. Altarum Institute Corp., 740 F.3d 325 (4th Cir. 2014), the United States Court of Appeals for the Fourth Circuit interpreted the ADA Amendments Act of 2008 (“ADAAA”), which  amended the Americans with Disabilities Act (“ADA”) to expand a previously limited definition of disability in federal employment cases.  Under the ADAAA, temporary impairments that are “sufficiently severe” are now considered to be disabilities, meaning that employees who suffer from short-term symptoms may be offered all the protection of the ADA if their condition is of high severity.  In Summers, the Fourth Circuit  implemented this new definition of disability and determined that a plaintiff who had injured himself in a train accident and who could not walk normally for seven months met the “sufficiently severe” requirement and was entitled to benefits and reasonable accommodation under the ADA.

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