The Sixth Circuit on Friday revived an Americans with Disabilities Act (ADA) failure-to-accommodate claim brought by the bankruptcy estate of Yazmin Torres-Duqum, a former physical therapist, against the University Hospitals Cleveland Medical Center. The appeals court found that the lower court failed to adequately investigate whether Torres-Duqum’s anxiety, PTSD, and depression qualified as a disability under the ADA.
Torres-Duqum filed the lawsuit in 2020, alleging that her former employer failed to accommodate her after she requested a job transfer due to panic attacks triggered by her mental health conditions. These attacks worsened following a miscarriage in 2016, and Torres-Duqum claimed that rumors about her leave further exacerbated her anxiety. Despite requesting a transfer to another site, the medical center denied her request, asserting that such accommodations were not available.
The lower court had dismissed her failure-to-accommodate claim, ruling that Torres-Duqum did not prove that her condition substantially limited her ability to work or perform other major life activities. However, the Sixth Circuit disagreed, emphasizing that the district court erred by not examining how Torres-Duqum’s PTSD and anxiety impacted major life activities beyond just work, such as thinking, concentrating, and interacting with others.
