PA FEDERAL COURTS ANALYZE PHRA DISABILITY CLAIMS UNDER PRE-ADAAA STANDARDS
The United States District Court for the Eastern District of Pennsylvania ruled in Riley v. St. Mary’s Medical Center that, while the ADA Amendments Act of 2008 (“ADAAA”) altered the federal standard for proving a disability under the Americans with Disabilities Act and as the Pennsylvania legislature has not enacted a similar amendment to the Pennsylvania Human Relations Act (“PHRA”), the higher, pre-ADAAA standard for proving “disability” will apply to a plaintiff’s PHRA disability claim.
Here, the plaintiff, Riley, was employed by the defendant St. Mary’s Medical Center for approximately ten years as a registered nurse. Riley had a history of suffering from colitis, anxiety, insomnia, and other cognitive issues. Riley alleged that she discussed her health conditions with her employer, St. Mary’s Medical Center,and that, soon thereafter, she was treated harshly, received negative performance reviews, and was terminated, all as a result of her disabilities. Riley alleged in her complaint that her medical conditions, “at times, limited her ability to enjoy several major life activities, including sleeping, concentrating, communication, and thinking (and this is not an exhaustive list).” On a motion to dismiss, St. Mary’s Medical Center challenged whether these allegations were sufficient to support disability discrimination claims under the ADA and PHRA.
As you will recall, before the ADAAA in 2008, the U.S. Supreme Court interpreted the definition of a disability strictly, as set forth in the often cited case of Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184. In Toyota, the Court had held that in order for an individual to be disabled, the individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives. With the ADAAA, Congress explicitly sought to reject the Supreme Court’s narrow interpretation of disability under the ADA. Under the ADA, as amended by the ADAAA, employees are no longer required to show that their impairment prevents or severely restricts major life activities.
Turning to the plaintiff’s allegations about her physical limitations, the court in Riley initially had to consider what standard applied to her PHRA claim of disability discrimination. Ultimately, the court ruled that, while the ADAAA altered the federal standard for proving a disability, the Pennsylvania legislature has not enacted a similar amendment to the PHRA; thus the plaintiff’s PHRA disability claim should be interpreted under the pre-amendment ADA standard for disability. Consequently, the court found that Riley had not pled the existence of a disability under the PHRA because her allegations failed to provide any facts illuminating to what extent her activities are limited, thus making it impossible to infer that she was substantially limited, as opposed to only mildly limited, in enjoying major life activities.
Because, for the most part, state employment laws like the PHRA are considered to provide protections to employees that are above-and-beyond those provided by their federal counterparts, it is particularly interesting that the court in Riley concluded that the PHRA places a higher burden on a plaintiff in a disability discrimination case than a case brought under the ADA. Given the court’s holding, do not be surprised if the PHRA’s disability protections are ultimately amended to track the changes that resulted by virtue of the ADAAA.