Statute Annotations › Federal › 29 C.F.R. § 1630.2

29 C.F.R. § 1630.2

Definitions under the Americans with Disabilities Act regulations: the cases that interpreted this section

Jurisdiction
Federal
Case notes
4,244
Cited in passing
892
Citing cases indexed
11,449
Case dates
1993–2026
Screened through
2026-06-26
Checked for later law changes
2026-10-01
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

5,136 citing cases reviewed of 11,449 in the citation index: 4,244 interpreted the section (annotated below), 892 cited it only in passing. Cases filed after 2026-06-26 may not have been reviewed yet.

Have a situation under 29 C.F.R. § 1630.2?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Substantial limitation in working

An impairment substantially limits working when it prevents a person from working at a particular job and a class or broad range of jobs.

Innes v. Mechatronics Inc. · filed 1997-07-17(j)(1)

An impairment does not substantially limit an individual's ability to work unless it prevents the person from working at a particular job and a class or broad range of jobs. See Holihan, 87 F.3d at 366; see also 29 C.F.R. § 1630.2(j)(1) ("substantially limits" means individual cannot perform, or is significantly restricted as to condition, manner or duration under which he can perform, a major life activity).
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A lifting restriction alone does not substantially limit the major life activity of working.

Merritt v. Boise Cascade Corp · filed 1999-12-20(j)(3)(i)

Such a lifting restriction alone does not constitute a substantial limitation on the major life activity of working.
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Section 1630.2(j)(3) requires a significant restriction in a class or broad range of jobs; inability to perform one particular job does not suffice.

Bowen v. Income Producing Management of Oklahoma, Inc. · filed 2000-02-01(j)(3)

Inability to perform a single, particular job is not a substantial limitation under the Act.
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Section 1630.2(j)(3)(i) requires a significant restriction in a class or broad range of jobs to establish a substantial limitation in working; inability to perform long-distance tractor-trailer driving alone does not qualify.

Equal Employment Opportunity Commission v. J.B. Hunt Transport, Inc. · filed 2003-02-05(j)(3)(i)

Driving freight-carrying tractor-trailer trucks over long distances for extended periods of time is neither a "class of jobs" nor a "broad range of jobs," as the EEOC alleges, but rather a specific job with specific requirements.
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A substantial limitation in working requires a significant restriction in a class or broad range of jobs; inability to perform one particular job is insufficient.

Zatarain v. WDSU-Television, Inc. · filed 1995-01-18(j)(3)(i)

In order for plaintiff to prevail on this argument, she must demonstrate more than an impairment of her ability to serve as a prime-time news anchor for WDSU. ... There is no evidence here that plaintiffs reproductive disorder significantly restricted her ability to perform a class of jobs or a broad range of jobs in various classes.
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Inability to perform one particular job does not substantially limit working; evidence that an impairment bars other jobs may create a factual dispute.

Eckles v. Consolidated Rail Corp. · filed 1995-07-05(j)(3)(i)

Concerning the single job theory, the Union has not shown that the yardmaster position at Avon is the only job Eckles is precluded from working because of his epilepsy. There are many jobs outside the yardmaster position that Eckles cannot perform because of his impairment, and the Union has not even shown that a significant number of other yardmaster positions do not also require the climbing of stairs to reach a tower. The evidence in favor of Eckles on this issue creates a genuine issue of fact as to whether he has a “disability” for purposes of the ADA.
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A restriction on heavy lifting does not substantially limit the major life activity of working unless it prevents a person from performing a class or broad range of jobs.

Farley v. Gibson Container, Inc. · filed 1995-07-17(j)(3)

He does not indicate, however, how this self-imposed lifting restriction “prevents [him] from performing an entire class of jobs,” Dutcher, 53 F.3d at 727, for it must be remembered that the term “working” does not, as Farley would have it, “refer to working at a particular job, or at a job of one’s choice.”
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An impairment substantially limits working only if it significantly restricts a person’s ability to perform a class of jobs or a broad range of jobs in various classes.

Kuehl v. Wal-Mart Stores, Inc. · filed 1995-11-14(j)(3)(i)

Because the Plaintiff fails to produce evidence showing a significant restriction in her ability to perform either a class of jobs or a broad range of jobs in various classes, she does not meet the definition of a disabled person under the ADA and the Defendants are entitled to summary judgment on her ADA claim.
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A claimant asserting a substantial limitation in working must provide evidence that the impairment disqualifies her from a class of jobs.

Terrell v. USAir, Inc. · filed 1996-02-09(j)(3)

Plaintiff has failed to show she is substantially limited in the major life activity of working because she provides no evidence of her disqualification from performing a class of jobs.
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Section 1630.2(j)(3)(i) provides that inability to perform a single, particular job does not substantially limit the major life activity of working.

Bell v. Elmhurst Chicago Stone Co. · filed 1996-03-12(j)(3)(i)

Elmhurst properly notes that Mr. Bell’s allegation that he is unable to perform his job for Elmhurst is not sufficient to establish a substantial limitation on his working. See 29 C.F.R. § 1630.2(j)(3)(i) (“The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.”).
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An impairment substantially limits working only if it restricts the person's ability to perform a class of jobs or a broad range of jobs in various classes.

Deghand v. Wal-Mart Stores, Inc. · filed 1996-04-11(j)(3)(i)

To defeat the summary judgment motion, the plaintiff must present evidence from which it could be reasonably found that her impairment restricts her ability to perform either a class of jobs or a broad range of jobs in various classes.
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A restriction from heavy manual labor alone does not establish a substantial limitation in working because manual labor includes other jobs.

Vaughan v. Harvard Industries, Inc. · filed 1996-05-10(j)(3)(i)

The ADA standard of a class or broad range of jobs, is not easily met; further, the job class, manual labor employment, is not limited to heavy manual labor jobs.
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An impairment substantially limits working only if it significantly restricts a person’s ability to perform a class or broad range of jobs; inability to perform one particular job is insufficient.

Aquinas v. Federal Express Corp. · filed 1996-09-26(j)(3)(ii)

Pursuant to the ADA, an individual’s “inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(ii). Rather, there must be a significant restriction on employment generally, i.e., on plaintiffs ability to perform “a class of jobs or a broad range of jobs” as compared to an average person of comparable skills and training.
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A limitation on working is substantial only if it significantly restricts the ability to perform a class of jobs or a broad range of jobs; difficulty working overtime at one job does not suffice.

Overton v. Tar Heel Farm Credit, ACA · filed 1996-09-30(j)

Even if plaintiff could prove that his inability to work overtime somehow limited his job performance with Tar Heel, the Fourth Circuit repeatedly has held that, as a matter of law, an employee cannot be deemed to have a substantially limiting impairment where he can show only that the limitation affects his ability to perform a particular job, but does not significantly restrict his ability to perform either a class of jobs or a broad range of jobs in various classes.
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An inability to perform one particular job does not substantially limit the major life activity of working.

Robinson v. Neodata Services, Inc., Susan M. Kipp Al Winston · filed 1996-10-04(j)(3)(i)

“The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” ... Because Robinson failed to establish that her physical impairment substantially limits one or more of her major life activities, or that she otherwise fits within the definition of disability, we conclude that the district court did not err in determining that Robinson is not disabled under the ADA.
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Law changed since The ADAAA and 2011 EEOC revision clarified that a short-term impairment can qualify as an actual disability; duration remains relevant to the individualized assessment.

Section 1630.2(j)(2) treats an impairment’s duration and expected long-term impact as factors in deciding whether it substantially limits working; a one-month inability to work that is not expected to recur with similar consequences does not qualify.

McIntosh v. Brookdale Hospital Medical Center · filed 1996-10-10(j)(2)

The decisive weight of authority holds that an impairment that prevents an individual from working for a period of one month, and that is not expected to recur with similar consequences in the foreseeable future, does not constitute a disability within the meaning of the ADA.
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An inability to perform one particular job does not substantially limit working under § 1630.2(j)(3)(i).

Kriskovic v. Wal-Mart Stores, Inc. · filed 1996-12-17(j)(3)(i)

The inability to do any one particular job does not constitute a substantial limitation on the major activity of working. 29 C.F.R. § 1630.2(j)(3)(i).
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A limitation on working must restrict a person’s ability to perform a class of jobs or a broad range of jobs; inability to perform a particular job is insufficient.

Zimmerman v. General Motors, Delphi Energy & Engine Management System Division · filed 1997-03-21(j)(3)

Defendant has shown that plaintiffs limitations did not rise to the level of “disability” by demonstrating that plaintiffs major life activity of work is not substantially limited. Plaintiff has failed to address the specific factors provided in the regulations and failed to provide any evidence that she was prevented from engaging in a wide class of jobs within her geographic area utilizing similar training.
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When working is the major life activity at issue, § 1630.2(j)(3)(ii) requires consideration of additional factors concerning the jobs from which the person is disqualified, geographic access, and job expectations and training.

Corrigan v. Perry · filed 1997-04-10(j)(3)(ii)

In cases in which “working” is the major life activity, however, the three additional factors contained in 29 C.F.R. § 1630.2(j)(3)(ii), and described by Forrisi, come into play.
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Section 1630.2(j)(3)(i) requires a substantial limitation on working generally; inability to perform a particular job or work for a particular supervisor alone does not establish disability.

Stroman v. Blue Cross and Blue Shield Ass'n · filed 1997-05-23(j)(3)(i)

Plaintiff was not precluded by her claimed disability from working generally, 29 C.F.R. § 1630.2(j)(3)(i), and her alleged inability to perform a particular job or work for a particular supervisor will not, without more, qualify her as disabled.
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An impairment affecting only a narrow range of jobs does not substantially limit the major life activity of working.

Boren v. Wolverine Tube, Inc. · filed 1997-05-28(j)(3)(i)

This court is also of the opinion that the plaintiffs impairment, assuming that one exists, only affects a narrow range of jobs and that she is thus not substantially limited in the major life activity of working.
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An impairment that prevents a person from performing only one particular job does not substantially limit the major life activity of working.

Foreman v. Babcock & Wilcox Co. · filed 1997-07-10(j)(3)

Because the evidence so overwhelmingly indicates that Foreman was substantially limited by his alleged disability from performing only a single, particular job, a jury could not reasonably find that he has a substantial limitation in the major life activity of working, as contemplated by the ADA.
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Section 1630.2(j)(3)(ii) permits consideration of the number and types of jobs from which an impairment disqualifies a person when assessing a claimed substantial limitation in working.

Piper v. Kimberly-Clark Corp. · filed 1997-07-14(j)(3)(ii)

Even assuming that the geographical area to which Plaintiff has reasonable access has few job opportunities regardless of a prospective employee’s impairment, Plaintiff has still failed to produce evidence showing the number and types of jobs from which Plaintiff is disqualified due to her impairment. In other words, Plaintiff’s summary judgment evidence does not satisfy the court’s concern that Plaintiff’s physical impairment merely disqualifies her from her past position as Stores Clerk.
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Symptoms that substantially limit a person's ability to perform a broad range of jobs can establish a substantial limitation in working.

McGill v. Callear · filed 1997-07-17(j)(3)(i)

There was sufficient evidence for the jury to find that plaintiffs symptoms substantially limited her ability to perform a broad range of jobs.
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A substantial limitation in working requires a restriction affecting a class or broad range of jobs.

Ingles v. Neiman Marcus Group · filed 1997-07-30(j)(3)

To be substantially limited in the major life activity of working, however, a person must be restricted in performing a class of jobs or a broad range of jobs as compared to the average person having similar training and abilities. ... It does not suggest Ingles is unable to perform a class or broad range of jobs, as required under the ADA.
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A substantial limitation in working must result from an impairment that significantly restricts the ability to perform a class or broad range of jobs; poor job prospects caused by age, education, or limited skills do not suffice.

Mondzelewski v. Pathmark Stores, Inc. · filed 1997-08-13(j)(3)

In order to prove this element of his claim, Mondzelewski must demonstrate he is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3). ... To hold Mondzelewski is substantially limited in the major life activity of work would permit him to gain protection from the ADA for personal characteristics that have nothing to do with his impairment. Accordingly, the Court holds Mondzelewski’s impairment does not create a significant limitation on his major life activity of working, and summary judgment will be granted for Pathmark on this issue.
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Section 1630.2(j) does not treat a person as substantially limited in working merely because an impairment bars a narrow range of jobs.

Lindloff v. Schenectady International · filed 1997-08-14(j)

It is true that Plaintiff is restricted from holding jobs that would expose him to phenolic compounds but being limited from such a narrow range of jobs does not qualify Plaintiff as being substantially limited in the major life activity of working.
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Section 1630.2(j)(3) treats a person as substantially limited in working when an impairment significantly restricts the ability to perform a class of jobs or a broad range of jobs compared with similarly qualified people.

Primeaux v. Conoco, Inc. · filed 1997-08-21(j)(3)

The evidence also is more than sufficient to create an issue of material fact as to whether Primeaux was significantly restricted in the ability to perform a class of jobs or a broad range of jobs in various classes, when compared with the ability of the average person with comparable qualifications to perform those same jobs.
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An inability to perform jobs requiring heavy physical exertion can substantially limit the major life activity of working when it excludes a broad class of jobs.

Valle v. City of Chicago · filed 1997-09-30(j)(3)(i)

We cannot see any principled distinction between a person disqualified from “any heavy labor job” and one disqualified from any job requiring “heavy physical exertion,” so we conclude that Valle has adequately alleged that he is substantially limited in the major life activity of working.
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Section 1630.2(j)(3) requires a significant restriction in the ability to perform a class or broad range of jobs; inability to perform one particular job is insufficient.

Cook v. Robert G. Waters, Inc. · filed 1997-10-02(j)(3)

The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working. ... Based on the evidence in the record, the Court finds that reasonable persons in the exercise of impartial judgment could not conclude that Plaintiff had a physical or mental impairment that substantially limited Plaintiffs ability to care for herself or to work.
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A person is substantially limited in working only if an impairment restricts a class of jobs or a broad range of jobs, rather than a single job.

Pinkerton v. City of Tampa, Fla. · filed 1997-10-21(j)(3)(i)

Application of this rule means that a person is not “disabled” merely because the person can no longer perform the job held before the onset of the impairment, unless the person is similarly disqualified from a class of jobs or a broad range of jobs in various classes as compared to the average, similarly situated person.
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When working is the major life activity, a lifting restriction must significantly limit the person's ability to perform a class or broad range of jobs to qualify as a substantial limitation.

McKiver v. General Electric Co. · filed 1997-12-04(j)(3)

Furthermore, Plaintiff offers no evidence to show that her lifting restriction significantly limited her ability to perform a broad range of jobs.
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A substantial limitation in working requires a significant restriction on the ability to perform a class of jobs or a broad range of jobs.

Watson v. Cencom Cable Income Partners · filed 1997-12-08(j)(3)(i)

Thus, the plaintiff carries the burden of establishing that his physical impairment significantly restricts his ability to perform “either a class of jobs or a broad range of jobs in various classes.”
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A person is substantially limited in working only if significantly restricted in the ability to perform a class or broad range of jobs.

Stuart v. Danka Corp. · filed 1997-12-12(j)(3)(i)

With respect to the major life activity of working, the term “substantially limits” means significantly restricted in the ability to perform a class of jobs or a broad range of jobs of various abilities. ... Plaintiff, however, does not present any evidence from which a reasonable juror could find that plaintiff was disabled within the meaning of the ADA, i.e., he could not work generally nor that his employment capabilities were limited in any way.
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An inability to perform a single particular job does not substantially limit the major life activity of working.

Parisi v. Coca-Cola Bottling Co. of New York · filed 1998-02-10(j)(3)(i)

Here, too, the plaintiff has alleged only that he has a knee injury that precludes his employment as a route deliveryman with Coca-Cola, and no more. In the Court’s view, the plaintiff has failed to state a “disability” as a matter of law, and for this reason alone, the complaint should be dismissed.
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An impairment that rules out only a narrow range of jobs requiring heavy lifting does not substantially limit the major life activity of working.

Schneider v. Chas. Seligman Distributing Co., Inc. · filed 1998-03-04(j)(3)(i)

Schneider’s impairment appears to disqualify him from only the narrow range of jobs that require him to physically load and unload items weighing in excess of twenty-five to thirty pounds. See McKay, 110 F.3d at 373. Accordingly, Schneider’s impairment is not a disability under the ADA.
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An inability to perform a single, particular job does not substantially limit the major life activity of working.

Cody v. Cigna Healthcare of St. Louis, Inc. · filed 1998-03-16(j)(3)(i)

This evidence did not rise to the level required to show a substantial limitation of a major life activity. See 29 C.F.R. 1630.2(j)(3)(i) (even an inability to perform a single, particular job does not constitute a substantial limitation on the major life activity of working).
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An impairment substantially limits working only if it limits employment generally, rather than the performance of a single, particular job.

Glowacki v. Buffalo General Hospital · filed 1998-04-09(j)(3)(i)

Furthermore, in analyzing whether plaintiffs major life activity of working is substantially limited, plaintiffs impairment must not only limit the performance of a “single, particular job,” but rather must limit employment generally. ... Here, plaintiff has not demonstrated that her impairment limits her employment generally.
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Section 1630.2(j)(3)(i) requires a limitation in working to extend beyond inability to perform a particular job of the person's choice.

Miller v. City of Springfield · filed 1998-06-24(j)(3)(i)

As the District Court correctly pointed out, however, working does not mean working at a particular job of the person's choice. We agree with the District Court's reasoning and conclude that the result is consistent with the law of this Circuit.
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Working is a major life activity, but inability to hold a particular job does not by itself substantially limit it.

Miller v. City of Springfield Richard R. Haymes Nora Duncan · filed 1998-07-30(i)

As the District Court correctly pointed out, however, working does not mean working at a particular job of the person’s choice. We agree with the District Court’s reasoning and conclude that the result is consistent with the law of this Circuit.
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Section 1630.2(j)(3)(i) requires a significant restriction in a class or broad range of jobs to establish a substantial limitation in working; moderate difficulty is insufficient.

White v. Stroh Brewery Co. · filed 1998-08-06(j)(3)(i)

We thus find that what plaintiff experienced was at most a moderate difficulty in working which is not sufficient, under existing Third Circuit precedent, to meet his burden of proving a disability within the meaning of the ADA.
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An impairment substantially limits working when it significantly restricts a person's ability to perform a class of jobs or a broad range of jobs in various classes.

Skorup v. Modern Door Corporation · filed 1998-08-26(j)(3)(i)

In this context, “substantially limits” means “significantly restricts the ability to perform a class of jobs or. a broad range of jobs in various classes.”
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A substantial limitation in working requires a significant restriction across a class or broad range of jobs; inability to perform one particular job is insufficient.

Horvath v. Savage Manufacturing, Inc. · filed 1998-09-03(j)(3)(i)

Horvath has failed to show any evidence that his asthma substantially impairs his ability to work as defined under the ADA regulations. It is true that Horvath’s asthma may impair him from painting in the conditions present at Mack, but this is insufficient to qualify as a substantial impairment of the major life activity of working under the ADA.
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A person is substantially limited in working only if the impairment significantly restricts their ability to perform a class of jobs or a broad range of jobs.

Gearhart v. Sears, Roebuck & Co., Inc. · filed 1998-10-19(j)(3)

In addition to the factors previously set forth, to determine if Gearhart’s depression substantially limits her ability to work, the court must consider whether Gearhart is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3). ... Gearhart submitted no evidence that her impairment impacted her ability to perform a class of jobs or a broad range of jobs in various classes.
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Section 1630.2 defines a substantial limitation by comparison with the general population and treats working as a major life activity; AIDS can satisfy that definition when it substantially limits a person's ability to work.

Wallengren v. Samuel French, Inc. · filed 1999-02-11(j)(1)(ii)

Furthermore, EEOC administrative regulations implementing the ADA define the term “substantially limits” to mean, in relevant part: “[significantly restricted as to the condition, manner or duration under which an individual can perform a particular major life activity as compared to the condition, manner, or duration under which the average person in the general population can perform that same major life activity.” 29 C.F.R. § 1630.2(j)(1)(ii). “Working” is defined as a major life activity under the EEOC regulations. 29 C.F.R. § 1630.2(i). In light of the substantially limiting effects of HIV and AIDS, as identified in Bragdon, on an individual’s ability to work, the court finds that plaintiffs AIDS condition is well within the meaning of “disability” under the ADA.
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Law changed since The ADAAA and 2011 EEOC revision replaced the old significant or severe restriction test with a broad, nondemanding substantial-limitation standard.

Section 1630.2 requires evidence that a mental impairment substantially limits a major life activity, such as working, to establish a disability.

Powell v. Morris · filed 1999-03-05(j)(1)

The term “substantially limits” means inability to perform, or a severe restriction on the ability to perform, as compared to the average person in the general population. ... Here, there is no evidence that Plaintiffs depression and anxiety substantially limited her ability to work.
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A person is substantially limited in working only if the impairment excludes them from a class of jobs or a broad range of jobs; inability to perform one particular job is insufficient.

Berg v. Norand Corporation · filed 1999-03-05(j)(3)

To establish that she is substantially limited in the life activity of working, Berg must show that she is limited from performing a class of jobs or a broad range of jobs within various classes. “The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” § 1630.2(j)(3)(i).
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A physical impairment substantially limits working when it significantly restricts a person’s ability to perform a class of jobs or a broad range of jobs, taking account of the jobs available in the person’s geographic area.

Quint v. A.E. Staley Manufacturing Company, Jacquelyn M. Quint v. A.E. Staley Manufacturing Company · filed 1999-04-07(j)(3)

In regard to the geographical/job class element, Quint established that her CTS restrictions did more than merely disqualify tier for a particular job at Staley.
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A claimant asserting a substantial limitation in working must show that the impairment disqualifies her from a class of jobs or a broad range of jobs in various classes.

Anderson v. General Motors Corp. · filed 1999-04-20(j)(3)

We also conclude that Anderson fails to show that she is substantially limited in the major life activity of working. She has the burden of proving that her impairment disqualified her from performing a “class of jobs” or a “broad range of jobs in various classes.” 29 C.F.R. § 1630.2(j)(3)(I); Siemon v. AT&T Corp., 117 F.3d 1173, 1176 (10th Cir. 1997).
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A person is substantially limited in working only if significantly restricted in performing a class of jobs or a broad range of jobs in various classes.

Marcum v. Consolidated Freightways · filed 1999-05-14(j)(3)(i)

To show that he is substantially limited in the “major life activity of working,” Plaintiff Marcum must show facts that he is “significantly restricted” in his ability to perform “either a class of jobs or a broad range of jobs in various classes,” compared to other workers with comparable training, skills, and abilities.
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A substantial limitation in working cannot rest on inability to perform one particular job; whether a claimant has a qualifying limitation may require factual development.

Dubee v. Henderson · filed 1999-06-29(j)(3)(i)

The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity or working. ... Whether she suffers from a “substantial limitation” on a major life activity, i.e., her employment, is a factual question. ... The Court cannot find there is no possibility that she suffers from a qualifying disability under the Rehabilitation Act.
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Law changed since The ADAAA and 2011 EEOC revision clarified that a short-term impairment can qualify as an actual disability; duration remains relevant to the individualized assessment.

A temporary inability to work lasting roughly three months does not substantially limit the major life activity of working.

Haiman v. Village of Fox Lake · filed 1999-07-07(j)(2)

Haiman’s inability to work was of a limited duration and was only temporary. Her leaves from work amount only to a time period of three to three and a half months, with the longest period lasting only a few days over two months. Even viewing the evidence in the light most favorable to Haiman, the court finds that the evidence shows that her inability to work was not permanent and was of such a limited duration that it was not a “substantial limitation” on her ability to work.
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A substantial limitation in working requires evidence that an impairment restricts a person from a class of jobs or a broad range of jobs.

Piascyk v. City of New Haven · filed 1999-07-14(j)(3)(i)

Plaintiff has failed to meet this burden. He has presented no evidence whatsoever concerning the kinds of jobs from which he is disqualified. Moreover, his evidence of restrictions would not in any event support a rational conclusion that he was unable to perform the requirements of even a single job, let alone a class or a broad range of jobs.
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An impairment substantially limits working only if it significantly restricts a person’s ability to perform a class or broad range of jobs; inability to perform one particular job is insufficient.

Long v. City of Leawood, KS · filed 2000-01-07(j)(3)(i)

Being unable to perform a single, particular job is not evidence of disability.
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A limitation on working is assessed by whether the impairment restricts a person’s ability to perform a class of jobs or a broad range of jobs compared with people of comparable training, skills, and abilities.

Hoover v. Norwest Private Mortgage Banking · filed 2000-02-15(j)(3)(i)

To show that her ability to work is materially limited by her impairments, Hoover must show that she is “restricted in [her] ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills, and abilities.”
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Law changed since The ADAAA and 2011 EEOC revision removed the requirement that an employer perceive a substantial limitation of a major life activity; an ADA-prohibited action because of an actual or perceived impairment generally suffices, subject to the transitory-and-minor exception.

An employer’s perception that an impairment prevents an employee from performing only one particular job does not substantially limit the major life activity of working.

Graves v. National Railroad Passenger Corp. · filed 2000-03-30(j)(3)(i)

Thus, if an employer perceives an employee’s impairment as limiting his ability to perform one job only, the employee is not disabled for ADA purposes.
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Section 1630.2(j)(3)(i) requires a significant restriction on a person's ability to perform a class or broad range of jobs; inability to work one employer's evening shift alone does not meet that standard.

Eibest v. Planned Parenthood of Stark County · filed 2000-04-21(j)(3)(i)

The regulations further provide that, when pertaining to the major life activity of working, the term “substantially limits” means “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i). ... Eibest’s speculation that most other nursing positions will entail similar shift requirements is unconvincing. Without some evidence to corroborate this speculation, Eibest cannot sufficiently demonstrate that she suffers from a disability under the ADA.
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Section 1630.2(j)(3)(i) requires a substantial limitation across a broad range of jobs; inability to work at one workplace is insufficient.

Nugent v. Rogosin Institute · filed 2000-07-06(j)(3)(i)

Nugent’s ability to secure and successfully perform a comparable job makes clear that her physical impairment did not substantially limit her ability to work, but only her ability to work for Rogosin. The ADA does not provide protection in such a situation.
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An impairment substantially limits working when it significantly restricts the person's ability to perform a class of jobs or a broad range of jobs.

Glover v. NMC Homecare, Inc. · filed 2000-07-11(j)(3)(i)

Plaintiff has presented no evidence whatsoever that his depression significantly restricted his ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.
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A substantial limitation in working is assessed against the abilities of people with comparable training, skills, and abilities.

Burns v. Coca-Cola Enterprises, Inc. Knoxville Coca-Cola Bottling Company, Inc. · filed 2000-07-24(j)(3)(i)

In making this determination, the reviewing court must decide whether the plaintiff is restricted in his or her ability to perform either “a class of jobs or a broad range of jobs in various classes” by reference to “the average person having comparable training, skills and abilities.”
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Law changed since Same change as noted above.

A claim that an employer regarded an employee as substantially limited in working requires evidence that the employer perceived a significant restriction in a class or broad range of jobs.

Williams v. Salvation Army · filed 2000-07-31(j)(3)(i)

Plaintiff bears the burden of presenting (some) evidence that Defendant perceived him to be “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs.” 29 C.F.R. § 1630.2(j)(3)(i); Ryan v. Grae & Rybicki, 135 F.3d at 872. Plaintiff fails to meet this burden.
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Section 1630.2(j)(3)(ii) does not require courts to consider the geographic location of available jobs when assessing whether an impairment substantially limits working.

Jones v. Ravens, Inc. · filed 2000-08-07(j)(3)(ii)

The regulations do not require the Court to consider what jobs are available in what location.
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A substantial limitation in working requires a significant restriction in a class or broad range of jobs; inability to perform one particular job is insufficient.

Sherman v. Peters · filed 2000-08-07(j)(3)(i)

Moreover, a plaintiff is only substantially limited in the major life activity of work is he is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(i) (1999); see also Heilweil v. Mount Sinai Hosp., 32 F.3d 718, 723 (2d Cir.1994).
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A severe knee impairment requiring medical leave and surgery can substantially limit the major life activity of working.

Ferguson v. Wal-Mart Stores, Inc. · filed 2000-09-28(j)(3)(i)

In the context of working, “substantially limits” means “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(i) (2000). ... Because the impairment was severe enough that (1) by mid-September 1997 Ms. Ferguson could not perform the essential functions of her job, (2) Ms. Ferguson requested a medical leave from September 23, 1997, until January 1998, (3) Ms. Ferguson underwent total knee replacement surgery on October 27, 1997, and (4) it was not known whether Ms. Ferguson’s condition could be successfully repaired by surgery, the Court finds that, as a matter of law, Ms. Ferguson had a physical impairment that substantially limited at least Ms. Ferguson’s major life activity of work.
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An inability to perform one particular job does not substantially limit working when the person can perform other jobs in the class.

Petty v. Freightliner Corp. · filed 2000-10-05(j)(3)

As such, the Court finds that though Plaintiff can no longer work as a truck assembler, he is not precluded from working in a class of jobs and is therefore not substantially limited in the major life activity of work.
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Section 1630.2(j)(3)(i) requires a significant restriction in the ability to perform a class of jobs or a broad range of jobs to establish a substantial limitation in working.

Hamilton v. Rheem Manufacturing Co. · filed 2000-10-06(j)(3)(i)

An impairment “substantially limits” an individual’s major life activity of working if it significantly restricts the individual’s “ability to perform either a class of jobs or a broad range of jobs in various classes.” ... Thus, while Plaintiff does have some medically imposed restrictions, she does not have an impairment that substantially limits her major life activity of working and she therefore does not have a disability as defined under the first prong of the ADA.
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An impairment substantially limits working when it significantly restricts a person’s ability to perform a class of jobs or a broad range of jobs.

Palao v. Fel-Pro., Inc. · filed 2000-10-20(j)(3)(i)

Palao has made no attempt to advance a theory under which a jury could find that her shoulder injury significantly restricts her “ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills, and abilities.” 29 C.F.R. § 1630.2(j)(3)(i). Because Palao has not met her burden, the Court grants Fel-Pro’s motion for summary judgment on her ADA claim.
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A substantial limitation in working requires inability to work in a broad class of jobs; inability to perform one particular job is insufficient.

Anderson v. ND State Hospital · filed 2000-11-14(j)(3)(i)

For Ms. Anderson to show that her ability to work has been substantially limited by her fear of snakes, however, she must show that she cannot work in a broad class of jobs. See Shipley v. City of University City, 195 F.3d 1020, 1023 (8th Cir. 1999); see also 29 C.F.R. § 1630.2(j)(3)(i).
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A substantial limitation in working requires an inability to work in a broad class of jobs; inability to perform one particular job is insufficient.

Marilyn Anderson, Appellant/cross-Appellee v. North Dakota State Hospital, Appellee/cross-Appellant · filed 2000-11-14(j)(3)(i)

For Ms. Anderson to show that her ability to work has been substantially limited by her fear of snakes, however, she must show that she cannot work in a broad class of jobs.
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A substantial limitation in working requires inability to work in a broad class of jobs; difficulty performing one particular job is insufficient.

Washington v. George G. Sharp, Inc. · filed 2000-12-20(j)(3)

Further, even assuming that Plaintiffs back injury impaired her ability to perform as a supply clerk, Ms. Washington fails to qualify as disabled for the additional reason that she has not demonstrated that she is unable to work in a broad class of jobs.
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Section 1630.2(j)(3)(ii) requires evidence about the number and types of jobs in the relevant local market to show that an impairment substantially limits working.

Duncan v. Washington Metropolitan Area Transit Authority · filed 2001-03-02(j)(3)(ii)

Without evidence of the number and kinds of jobs available to Duncan the jury had no basis to find he was disqualified from a substantial class or broad range of them.
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A substantial limitation in working requires a significant restriction in the ability to perform a class of jobs or a broad range of jobs.

Ahmed v. Gelfand · filed 2001-03-05(j)(3)(i)

A substantial limitation in the major life activity of working is defined as being “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes.” 29 C.F.R. § 1630.2(j)(3)(i). As Plaintiff does not allege such a restriction, he is unable to establish a prima facie case under the ADA.
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A plaintiff’s evidence that an impairment precludes a broad range of jobs can permit a finding that the plaintiff is substantially limited in working.

Maziarka v. Mills Fleet Farm · filed 2001-04-03(j)(3)(i)

Maziarka has also presented evidence that he is precluded from performing a broad range of jobs, not simply the receiving job at Fleet Farm. ... Accordingly, we conclude that Maziarka has presented evidence that would allow a trier of fact to find Maziarka to be disabled--substantially limited in the major life activity of working--within the meaning of the ADA.
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Law changed since Same change as noted above.

An employer’s belief that a person cannot do any job at its plant can support a perceived limitation in a class of jobs if the plant’s jobs reflect a broader class of similar work.

Henderson v. Ardco, Inc. · filed 2001-04-24(j)(3)(ii)(B)

Plaintiff has brought forward evidence that the defendant perceived there was no job for her at the Ardeo plant, and this gives an indication of the employer’s perception about her suitability for a class of relevantly similar employment. Further factual inquiry must determine whether the range of essential job functions at the plant, in actuality as well as on paper, was roughly equivalent to the class of “manufacturing jobs.”
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A person is substantially limited in working only if the impairment significantly restricts their ability to perform a class of jobs or a broad range of jobs.

Johnston v. Henderson · filed 2001-05-01(j)(3)(i)

To be substantially limited in the major life activity of “working,” the individual must be significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes compared to the average person having comparable training skills and abilities.
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Law changed since Same change as noted above.

A substantial limitation in working must affect a class of jobs or a broad range of jobs; perceived inability to perform one job is insufficient.

Greco v. County of Nassau · filed 2001-05-29(j)

Even if Plaintiff could show a perception of being unable to perform all functions necessary to the job of Corrections Officer (which he cannot) this, standing alone, would be insufficient to state a claim of disability under the ADA. The inability to perform this single job does not constitute a substantial limitation on the ability to work.
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Section 1630.2(j)(3)(i) requires a substantial limitation in working to restrict a person’s ability to perform a class or broad range of jobs; inability to perform one particular job is insufficient.

Richio v. Miami-Dade County · filed 2001-06-04(j)(3)(i)

With respect to the major life activity of working, the EEOC defines “substantially limits” to mean “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(i). ... Similarly, Plaintiff has not alleged or demonstrated that she was unable to work in a broad class of jobs.
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A plaintiff claiming a substantial limitation in working must show a significant restriction in the ability to perform a class of jobs or a broad range of jobs in various classes compared with people of similar training, skills, and abilities.

Cutler v. Hamden Board of Education · filed 2001-06-29(j)(3)(i)

While we recognize that the determination of whether plaintiff is disabled requires an “individualized inquiry,” Sutton v. United Air Lines, Inc., 527 U.S. 471, 482, 119 S.Ct. 2139, 144 L.Ed.2d 450 (1999), the burden remains with the plaintiff to point to some credible evidence that she is significantly restricted in her ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. See 29 C.F.R. § 1630.2(j)(3)(i). This she has failed to do.
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A person is substantially limited in working only if significantly restricted in performing a class of jobs or a broad range of jobs compared with people of comparable training, skills, and abilities.

Boyer v. KRS Computer & Business School · filed 2001-09-10(j)(3)(i)

To establish that Sehnitker and Tamble's attitudes caused Boyer to be limited in the major life activity of working, Boyer must demonstrate that their attitudes caused him to be "significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i). There is no such evidence before the Court.
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An impairment substantially limits working only if it significantly restricts the ability to perform a class of jobs or a broad range of jobs; inability to perform one particular job is insufficient.

Keating v. Gaffney · filed 2001-09-12(j)(3)(i)

However, this Court finds that the inability to perform this narrow range of tasks does not “substantially limit” Keating’s ability to perform the major life activity of working. Indeed, the position of an Engineering Aide in the Highway Construction Division of the DPW, and particularly, the Aide who measures asphalt, is a single, particular job, a limitation of which cannot constitute a substantial limitation of the major life activity of working.
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A lifting restriction alone is insufficient to establish a substantial limitation in the major life activity of working.

Davila v. Hilton International of Puerto Rico, Inc. · filed 2001-09-28(j)(3)

First, the Court holds that a lifting restriction alone is not sufficient to establish a substantial impairment to the major life activity of working.
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A substantial limitation in working requires evidence that the impairment restricts a person from performing a class of jobs or a broad range of jobs in various classes.

MacGovern v. Hamilton Sunstrand Corp. · filed 2001-11-08(j)(3)(i)

While mandatory overtime may have been required at his job on the weekend in question, there is no evidence in the record that MacGo-vern’s inability to work mandatory overtime precludes him from performing “a class of jobs or a broad range of jobs in various classes,” which is what he must show in order to be substantially limited in the major life activity of working.
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A person is substantially limited in working only if the impairment significantly restricts the ability to perform a class of jobs or a broad range of jobs.

Thompson v. Archer Daniels Midland Co. · filed 2001-12-05(j)

In discussing the major life activity of working, “substantially limits” means the individual is significantly restricted in the ability to perform a class of jobs or a broad range of jobs in various classes. ... Based upon Contreras, this evidence is insufficient to show that he was substantially limited in the major life activity of working.
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An inability to work more than eight hours a day does not substantially limit working without evidence that it prevents work across a broad class of jobs.

Boerst v. General Mills Operations, Inc. · filed 2002-01-15(j)(3)(i)

Boerst says that he suffers a substantial limitation on his ability to work because he can work no more than eight hours a day. Like Boerst’s allegation and evidence about sleepless nights, this allegation and its supporting evidence cannot show a substantial limitation under the ADA.
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Evidence that a perceived physical restriction would exclude a person from a broad range of nearby jobs can support a finding of substantial limitation in working.

Harshbarger v. Sierra Pacific Co. · filed 2002-01-15(j)(3)(ii)(C)

Howden explained that “just based on the physical preclusions in the world of work, Mr. Harshbarger would be limited to nearly 40% of the jobs performed within reasonable commuting distance of his home.” This evidence is precisely the sort contemplated by the EEOC guidelines for establishing disqualification from a “broad range of jobs in various classes.” 29 C.F.R. § 1630.2(j)(3)(ii)(C).
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Inability to work in a particular position does not substantially limit the major life activity of working.

Power v. England · filed 2002-02-20(j)(3)(i)

With respect to the major life activity of working, the inability to work at a particular position does not render an employee substantially limited.
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A substantial limitation in working requires a restriction affecting a class or broad range of jobs; difficulty performing one job function is insufficient.

Sacay v. Research Foundation of the City University of New York · filed 2002-03-27(j)(3)

Thus, at most, Valerie has shown that she was substantially limited in her ability to perform a particular job function, catalog production, “[b]ut the inability to satisfy the requirements of a particular assignment does not mean such a person is regarded as handicapped.... To meet that definition, the employee’s impairment must limit her employment generally.”
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An impairment substantially limits working only if it precludes the person from a substantial class of jobs.

Palotai v. University of Maryland · filed 2002-06-27(j)(3)(i)

... he must show that this disability pre- cluded him from a substantial class of jobs. See 29 C.F.R. § 1630.2(j)(3)(i). This he has not done.
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A person may show a substantial limitation in working by showing a significant restriction in the ability to perform either a class of jobs or a broad range of jobs in various classes.

Black v. Roadway Express, Inc. · filed 2002-07-22(j)(3)(i)

Second, the district court did not separately address whether Black’s knee injury significantly restricted him from a class of jobs or from a broad range of jobs in various classes. In order to demonstrate substantial limitation in the major life activity of working, Black needed only to demonstrate that he is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i) (emphases added); see also McKay v. Toyota Motor Mfg., U.S.A., Inc., 110 F.3d 369, ... 372-73 (6th Cir.1997).
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Law changed since The 2011 EEOC revision removed the former required vocational and geographic factor checklist for substantial limitation in working; the class-or-broad-range inquiry remains.

Whether an impairment substantially limits a person’s ability to work depends in part on vocational training, the accessible geographic area, and the jobs the impairment forecloses.

Aurigue v. Potter · filed 2002-08-26(j)(3)(ii)

She submits no evidence addressing her vocational training, the geographical area to which she has access, or the number and type of jobs from which she is disqualified because of her impairment. See 29 C.F.R. § 1630.2(j)(3)(ii) (listing such demographic factors as central to the determination of whether an individual is substantially limited in her ability to work).
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A person regarded as limited in working must be perceived as unable to perform a class or broad range of jobs; inability to perform one job is insufficient.

Cameron v. Community Aid for Retarded Children, Inc. (Keon Center) and William Melville · filed 2003-07-08(j)(3)(i)

“The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.”
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Law changed since The ADAAA (effective Jan. 1, 2009) and 2011 EEOC revision removed the former significant-restriction threshold; the class-or-broad-range inquiry for actual disability based on working remains.

Working is a major life activity, but a substantial limitation in working requires a significant restriction in a class or broad range of jobs.

Martinez v. Celulares Telefonica, Inc. · filed 2003-07-17(j)(3)(i)

According to the EEOC Regulations, “working” is a major life activity and it is substantially limited when a plaintiff is “(i) ... significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(i), § 1630.2(j)(3)(i)(2001); Gelabertr-Ladenheim, 252 F.3d at 58. Sa-lamo has offered absolutely no evidence that he is precluded from engaging in this or other types of gainful employment.
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An inability to perform one particular job does not substantially limit working; the impairment must preclude a substantial class of jobs.

Jones v. FAMILY HEALTH CENTERS, INC. · filed 2003-08-12(j)(3)(i)

When the major life activity at issue is working, “[t]he inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(i). Rather, Jones must show that the disabilities precluded her from a substantial class of jobs. See 29 -C.F.R. § 1630.2(j)(3)(i). This she has not done.
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A person is substantially limited in working only if an impairment restricts the ability to perform a class of jobs or a broad range of jobs in various classes; difficulty with a single job is insufficient.

Lane v. Bell County Board of Education · filed 2003-08-12(j)(3)(i)

In this case, as noted by the district court. Lane did not submit any evidence tending to show that her PTSD restricts her ability to perform either an entire class of jobs or a broad range of jobs in various classes.
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Law changed since The ADAAA and 2011 EEOC revision removed the requirement that an employer perceive a substantial limitation of a major life activity; an ADA-prohibited action because of an actual or perceived impairment generally suffices, subject to the transitory-and-minor exception.

A substantial limitation in working concerns a class or broad range of jobs; an employer’s refusal to let an employee work in any capacity can raise a factual question about whether it regarded the employee as so limited.

Medlin v. Rome Strip Steel Co., Inc. · filed 2003-12-10(j)(3)(i)

Taking the facts in the light most favorable to plaintiff, a factual question exists as to whether RSS perceived that plaintiffs back condition substantially limited him in the major life activity of working. Indeed, it is difficult to even reach the inquiry, as RSS flat-out refused to allow plaintiff to work in any capacity for the company, let alone the job he previously held.
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Law changed since Same change as noted above.

An employer does not regard a person as substantially limited in working merely because it considers her unable to perform one particular job.

Gordon v. MCG Health, Inc. · filed 2003-12-15(j)(3)(i)

Because the position of staff nurse was a single job, the plaintiffs allegation does not support the claim that the defendant regarded her as having a substantially limiting impairment.
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An impairment substantially limits working when it significantly restricts access to a class or broad range of jobs compared with people of similar training, skills, and abilities.

Lilly v. Mastec North America, Inc. · filed 2004-01-12(j)(3)

However, the key question to be answered is not whether plaintiff is excluded from a class or broad range of jobs due to his lack of education, training, experience, etc., but whether he is excluded from such jobs at a substantially greater rate because of his impairment given his education, training, etc.
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A substantial limitation in working requires a significant restriction in the ability to perform a class or broad range of jobs; inability to perform one particular job is insufficient.

Potenza v. City of New York · filed 2004-04-23(j)(3)

Athough “major life activities” include both working and walking, 29 C.F.R. § 1630.2(h)(2)(i), Potenza cannot show that these life activities were “substantially limited” by his injury. When the major life activity involved is working, “substantially limits means significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.”
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A substantial limitation in working requires a significant restriction in the ability to perform a class or broad range of jobs; difficulty performing one job is insufficient.

Prejean v. Cypress-Fairbanks Independent School District · filed 2004-05-11(j)(3)(i)

Prejean attested that his depression required him to take time off from work from his job as a buyer, but did not raise a question of fact about whether his depression rendered him unable to work in a broad class of jobs.
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A substantial limitation in working requires an impairment that excludes a person from a class of jobs or a broad range of jobs; inability to perform one particular job is insufficient.

Martin v. Town of Westport · filed 2004-08-04(j)(3)

Only a single, specific job, that of Master Mechanic, is at issue in this case, and Mr. Martin does not claim, let alone provide any evidence that would allow a trier of fact to conclude, that his impairment excluded him from a class of jobs or a broad range of jobs.
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A person may be substantially limited in working if an impairment significantly restricts access to a class of jobs requiring similar training, knowledge, skills and abilities, even when other kinds of work remain available.

Edward R. Williams Angelynne Williams, H/w v. Philadelphia Housing Authority Police Department, Edward R. Williams · filed 2004-08-26(j)(3)(i)

It is clear from the regulations that, even if one has the ability to perform a broad range of jobs, one is nevertheless disabled if one is significantly restricted in one’s ability to perform most of the jobs in one’s geographical area that utilize training, knowledge, skills and abilities similar to the job one has been disqualified from performing.
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Law changed since Same change as noted above.

A person is substantially limited in working when significantly restricted from performing a class of jobs or a broad range of jobs, rather than a single job.

Senter v. Hillside Acres Nursing Center of Willard, Inc. · filed 2004-09-14(j)(3)(i)

The Court finds Plaintiffs testimony about Hicks’s statement sufficient to create a genuine issue of material fact as to whether Hicks terminated Plaintiff because Hicks believed Plaintiffs ability to perform either a class of jobs or broad range of jobs in various classes was significantly restricted compared to the average person with comparable training, skills, and abilities.
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Law changed since Same change as noted above.

An employer regards a person as substantially limited in working only if it perceives the person as unable to perform a class of jobs or a broad range of jobs; inability to perform one particular job does not suffice.

Equal Employment Opportunity Commission v. Daimler Chrysler Corp. · filed 2004-09-15(j)(3)(i)

With respect to “working,” “[t]he term substantially limits means significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i) (emphasis in original). ... In sum, because the evidence demonstrates only that DCC regarded Diem as unable to perform the particular job of jitney repair mechanic, the EEOC has not created a genuine issue of material fact as to whether DCC regarded Diem as “substantially limited” in working.
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A person is substantially limited in working when an impairment significantly restricts their ability to perform a class of jobs or a broad range of jobs in various classes.

Vaughn v. Harvey · filed 2005-07-07(j)(3)(i)

The district court during trial properly granted the Army judgment as a matter of law after the close of Vaughn’s case because Vaughn did not establish that she is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” See Thompson v. Holy Family Hosp., 121 F.3d 537, 540 (9th Cir.1997) (per curiam) (quoting 29 C.F.R. § 1630.2(j)(3)(i)). That Vaughn had to work no more than 40 hours a week, that she be restricted in climbing stairs, and that she wear comfortable clothing do not suggest that she could not perform either a class of jobs or a broad range of jobs in various classes.
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A person claiming a substantial limitation in working must show that an impairment restricts them from a class of jobs or a broad range of jobs in various classes.

Parker v. City of Williamsport · filed 2005-12-21(j)(3)(ii)(A)-(C)

Plaintiff has presented none of this evidence and therefore no reasonable jury could find Parker substantially impaired in the major life activity of working.
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A limitation on working must prevent a person from performing a broad class of jobs; inability to perform one particular job is insufficient.

Gretillat v. Care Initiatives · filed 2006-02-13(j)(3)(i)

It is well settled, however, that an inability to perform one particular job is not a substantial limitation on working. ... Because Gretillat has introduced no evidence of an inability to work in a broad class of jobs, she is not substantially disabled in the life activity of working.
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Law changed since The ADAAA (effective Jan. 1, 2009) and EEOC’s 2011 revision replaced the old significant or severe restriction test with a broad, nondemanding substantial-limitation standard.

A person is substantially limited in a major life activity when an impairment significantly restricts the person’s ability to perform it compared with the average person.

MacChia v. Loyola University Medical Center · filed 2006-03-28(j)(ii)

Even assuming that Plaintiff has correctly stated the nature of her impairment, this Court concludes that the impairment as described by Plaintiff does not qualify as a disability recognized by the ADA.
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Law changed since The ADAAA and 2011 EEOC revision removed the requirement that an employer perceive a substantial limitation of a major life activity; an ADA-prohibited action because of an actual or perceived impairment generally suffices, subject to the transitory-and-minor exception.

A person regarded as substantially limited in working must be perceived as significantly restricted from performing a class of jobs or a broad range of jobs.

Equal Employment Opp v. Burlington Northern · filed 2006-11-29(j)(3)(i)

To prevail on its claim, the EEOC was required to demonstrate that Burlington viewed the perceived left-arm and grip-strength weakness as significantly restricting M r. Freeman’s ability to perform a class of jobs.
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A substantial limitation on working requires evidence that an impairment excludes a person from a class or broad range of jobs; the person need not identify a precise number of jobs but may need to show approximately how many are excluded.

Corley v. Department of Veterans Affairs · filed 2007-02-20(j)(3)

Mr. Corley was not required to present evidence of a precise number of jobs from which he was disqualified because of his impairment. But in his circumstances he did need to present “evidence of general employment demographics and/or of recognized occupational classifications that indicate the approximate number of jobs (e.g., ‘few,’ ‘many,’ ‘most’) from which [he] would be excluded.”
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An impairment substantially limits working when it significantly restricts a person’s ability to perform a class of jobs or a broad range of jobs.

Curcio v. Bridgeport Board of Education · filed 2007-03-15(j)(3)

This minimal evidence does not show that Curcio’s claimed impairment substantially limits her ability to perform a class of jobs or a broad range of jobs in various classes.
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A person is substantially limited in working only if an impairment significantly restricts the ability to perform a class of jobs or a broad range of jobs.

Ramirez v. New York City Board of Education · filed 2007-03-30(j)(3)(i)

To prove a substantial limitation on the major life activity of working, a plaintiff must show that he is “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i); see also Murphy v. United Parcel Serv., Inc., 527 U.S. 516, 523, 119 S.Ct. 2133, 144 L.Ed.2d 484 (1999). ... Ramirez’s impairments during the 2000-2001 school year do not rise to a level of substantially limiting Ramirez from the major life activity of working.
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Law changed since Same change as noted above.

A substantial limitation on working can arise when an employer regards an impairment as preventing work across a class of jobs, including jobs operating vehicles and heavy equipment.

Russo v. SYSCO Food Services of Albany, L.L.C. · filed 2007-05-21(j)(3)(i)

This indicates that SYSCO regarded plaintiff as unable to work in any job requiring the operation of trucks, forklifts, or any other company vehicle. Positions requiring the operation of all vehicles and heavy equipment constitutes a class of jobs. Thus, plaintiff has shown that SYSCO regarded his epilepsy as a substantial limitation on his ability to work.
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A person is substantially limited in working only if an impairment precludes a class of jobs or a broad range of jobs in various classes.

Delacruz v. TRIPLER ARMY MEDICAL · filed 2007-07-24(j)(3)(i)

To be considered substantially limited in the major life activity of working, a person must be precluded from performing “ ‘either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.’ ” 29 C.F.R. § 1630.2(j)(3)(i); ... Plaintiff presented no evidence that she is precluded from performing a class of jobs or a broad range of jobs.
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Section 1630.2(j)(3)(i) requires a substantial limitation in working to affect a class or broad range of jobs; inability to perform one particular job is insufficient.

Gentile v. Potter · filed 2007-09-06(j)(3)(i)

The “inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” 29 C.F.R. § 1630.2(j)(3)(i). ... Therefore, this Court is hard-pressed to find that Gentile was limited in his ability to perform his own job, far from being substantially limited in his ability to perform a broad range of jobs.
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Law changed since Same change as noted above.

A substantial limitation in working requires an inability to work in a class of jobs or a broad range of jobs; inability to perform one specialized job is insufficient.

Rodriguez v. City of New York · filed 2008-02-11(j)(3)(i)

If plaintiff was terminated because of her perceived claustrophobic condition, there is absolutely no evidence that the defendants believed she was unable to work in either “a class of jobs or a broad range of jobs.” 29 C.F.R. § 1630.2(j)(3)(i); rather, assuming she was in fact terminated for this perceived condition, the only evidence in the record on this issue is that the recommendation for termination was based on her perceived inability to perform the specialized duties of a police officer because of the condition.
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An impairment substantially limits working only if it significantly restricts the ability to perform a class or broad range of jobs; difficulty performing one job is insufficient.

Bonieskie v. Mukasey · filed 2008-03-31(j)(3)(i)

Mr. Bonieskie has offered not even a scintilla of evidence that his impairments significantly restricted his ability to perform a class or broad range of jobs.
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Section 1630.2(j)(3)(i) requires a substantial limitation in working to affect a class of jobs or a broad range of jobs; inability to perform one particular job is insufficient.

Levine v. Smithtown Central School District · filed 2008-07-14(j)(3)(i)

The Court also notes that an inability to perform a single, particular job does not constitute a substantial limitation on the major life activity of working.
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A substantial limitation in working requires an inability to work in a broad range of jobs, rather than only a specific job.

Kiesewetter v. Caterpillar Inc. · filed 2008-10-09(j)(3)

A substantial limitation means “inability to work in a broad range of jobs, rather than a specific job.” Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184, 200, 122 S.Ct. 681, 151 L.Ed.2d 615 (2002); see also 29 C.F.R. § 1630.2(j)(3). Kiesewetter contends that his bipolar disorder prevents him from working as an engineer at Caterpillar but has never tried to show that it prevents him from working at a “broad range of jobs”.
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A substantial limitation in working requires a significant restriction in the ability to perform a class of jobs or a broad range of jobs.

Young v. PRECISION METAL PRODUCTS, INC. · filed 2009-02-11(j)(3)

Young has not offered evidence to show he is, or ever was, significantly restricted in the ability to perform either a class of jobs or a broad range of jobs.
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A substantial limitation on working requires a significant restriction in a class of jobs or a broad range of jobs in various classes.

Fournier v. Payco Foods Corp. · filed 2009-05-01(j)(3)(i)

At any rate, Fournier does not carry his burden to show that he was restricted as to either a class of jobs or a broad range of jobs in various classes, and this constitutes a second basis for the Court’s holding that Fournier was not disabled within the meaning of the ADA.
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A restriction to sedentary work can plausibly indicate a substantial limitation in the major life activity of working at the pleading stage.

Fowler v. SHADYSIDE · filed 2009-08-18(i), (j)(3)

Furthermore, her alleged limitation to sedentary work plausibly suggests that she might be substantially limited in the major life activity of working.
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A limitation on the ability to perform one job does not establish a substantial limitation in working; the person must be unable to work in a broad class of jobs.

Kania v. Potter · filed 2009-12-22(j)

Finally, even accepting that Kania experiences limitations on his ability to work as a letter carrier, he has not demonstrated that these limitations make him “unable to work in a broad class of jobs.”
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A substantial limitation in working requires disqualification from a class or broad range of jobs; that requirement does not apply to other major life activities.

Miller v. Hersman · filed 2010-01-04(j)(3)(i)

First, as Plaintiff points out, the requirement that a plaintiff employee be disqualified from a class or broad range of jobs only applies when the major life activity claimed to be substantially limited is that of working.
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Law changed since Same change as noted above.

A substantial limitation in working must restrict a person’s ability to perform a class of jobs or a broad range of jobs.

Brown v. City of Waterbury Board of Education · filed 2010-06-28(j)(3)

The court must therefore consider whether the defendants perceived Brown as restricted in his ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. ... In this case, Brown cannot establish that the defendants perceived him as “disabled” within the meaning of the ADA, because he has presented no evidence that the defendants perceived him as suffering from impairments that would “substantially limit” his ability to “work.”
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The regulation assesses substantial limits on working by the classes and range of jobs available to a person, regardless of whether those jobs offer the same schedule or an accommodation.

Perry v. Kappos · filed 2011-03-02(j)(3)(ii)(B)

The inquiry is not whether those jobs also provided the same or a different schedule or whether they provide any accommodation.
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Law changed since Same change as noted above.

A person regarded as substantially limited in working must be perceived as unable to perform a class of jobs or a broad range of jobs; difficulty with one task is insufficient.

Perez v. SAINT JOHN'S SCHOOL · filed 2011-09-30(j)(3)(i)

At most, taken in context, the deposition testimony shows that Hequin and Farnham doubted Plaintiffs ability to perform a single task — that of completing mailings. Such a showing is insufficient to fulfill the first prong of the prima facie standard for discrimination under the ADA.
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Section 1630.2(j)(3)(i) requires a substantial limitation in working to restrict a person’s ability to perform a class of jobs or a broad range of jobs.

Laws v. HealthSouth Northern Kentucky Rehabilitation Hospital Ltd. Partnership · filed 2011-11-01(j)(3)(i)

A plaintiff instead must show that she is “ ‘significantly restricted in ability to perform either a class of jobs or a broad range of jobs in various classes.’ ” Id. (quoting 29 C.F.R. § 1630.2(j)(3)(i)) (emphasis added); see also, e.g., Milholland v. Sumner Cty. Bd. of Educ., 569 F.3d 562, 568 (6th Cir.2009) (citing same).
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Section 1630.2(j)(3) requires a substantial limitation in working to restrict a class or broad range of jobs; difficulty with one job or work skill is insufficient.

Robinson v. Purcell Construction Corp. · filed 2012-03-14(j)(3)

“The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.” ... the inability to perform this individual “work skill” does not constitute an impairment of a major life activity such to qualify under the ADA.
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Law changed since The ADAAA (effective Jan. 1, 2009) and EEOC’s 2011 revision replaced the old significant or severe restriction test with a broad, nondemanding substantial-limitation standard. For actual disability based on working, the class or broad range of jobs inquiry remains.

Under the pre-2011 regulation, a substantial limitation on working requires a significant restriction in a class of jobs or a broad range of jobs.

Joseph v. North Shore University Hospital · filed 2012-04-03(j)(3)(i)

Joseph did not adduce sufficient evidence to support a finding that she was “significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities.” 29 C.F.R. § 1630.2(j)(3)(i) (1991), superseded by 29 C.F.R. § 1630.2(j) (2011).
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Section 1630.2 requires a plaintiff claiming a substantial limitation in working to allege restrictions on performing a class or broad range of jobs.

Issa v. Delaware State University · filed 2017-08-04(j)(3)(I)

In order to allege a disability under the ADA that substantially limits the major activity of working,, a plaintiff must plead restrictions in his “ability to perform either a class of jobs or a broad range of jobs.” ... As the Amended Complaint lacks any such allegation, the Court will dismiss íssa’s ADÁ claim.
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Definition of physical impairment

Cancer is an impairment under the ADA’s definition of disability.

Oehmke v. Medtronic, Inc. · filed 2016-12-22(h)(1)

Cancer is an impairment, 29 C.F.R. § 1630.2(h)(1), the functioning of one's immune system is a major life activity, 42 U.S.C. § 12102(2)(B), and Congress has instructed the courts to determine whether a limitation is substantial in ... light of its command to interpret disability broadly, 42 U.S.C. § 12102(4)(B); ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. ... Therefore, Oehmke's cancer, even while in remission, is clearly a covered disability under the ADA.
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Section 1630.2(h)(1) includes conditions affecting the neurological system within the definition of a physical impairment.

Equal Employment Opportunity Commission v. M.G.H. Family Health Center · filed 2017-01-30(h)(1)

Here, there is no dispute in material fact that during the relevant time period, Lane suffered: a) severe migraines, and b) thoracic outlet syndrome, both of which Workplace Health considered as “impairments” because of the perceived effects of those conditions on Lane’s neurological system, see 29 C.F.R. § 1630.2(h)(1), and neither of which were “transitory and minor.”
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Section 1630.2(h)(1) defines physical impairment broadly to include a physiological condition affecting a body system, including the immune system.

SIKO · filed 2025-12-10(h)(1)

In this Court’s estimation, the portion of 29 C.F.R. § 1630.2(h)(1) that posits a regulatory definition of “physical impairment” to include a physiological condition that affects the immune system is congruent with this Court’s independent textual and contextual interpretation of the statutory term “impairment” as used in 42 U.S.C. § 12102(1)(C) and (3)(A). This regulation offers no reasons to change the Court’s interpretation of the statutory term “impairment” or its application to Siko’s pleadings. Rather, it confirms it.
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Section 1630.2(h)(1) defines an impairment to include a physiological disorder or condition affecting specified body systems, and a rotator-cuff injury plausibly qualifies when it substantially limits the major life activity of working.

MELTON v. SOUTHEASTERN PENNSYLVANIA TRANSIT AUTHORITY (SEPTA) · filed 2024-03-18(h)(1)

The accompanying agency regulation reflects this broad mandate, defining an impairment as “[a]ny physiological disorder, or condition ... affecting one or more of the following body systems: neurological, musculoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genito-urinary, hemic and lymphatic, skin, and endocrine.” ... When any of these genres of impairments significantly restricts “as to the condition, manner, or duration” a major life activity, an individual is disabled. ... Melton has both adequately alleged she suffered from a “disability” under the ADA and that she was fired as a result of her disability. Her Complaint is brief, but direct. She suffered a torn-rotator cuff on January 14, 2022 and requested time off, from work, to address her injury. Compl. at 6. It is common sense, let alone a plausible inference, that Melton asked for time off because the rotator cuff was substantially limiting her ability to work, a major life activity.
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Section 1630.2(h)(1) treats anatomical loss affecting a body system as a physical impairment.

Collins v. Board of County Commissioners of Nowata County · filed 2023-06-06(h)(1)

The absence of Mr. Collins’ left hand reasonably constitutes an “anatomical loss” affecting a body system as required by 29 C.F.R. § 1630.2(h)(1) to be considered a “physical impairment.”
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Section 1630.2(h)(1) treats a physiological condition affecting the cardiovascular system as an impairment, so heart disease qualifies as an ADA impairment.

Wilson v. Georgia-Pacific Corp. · filed 1998-03-31(h)(1)

In this case, plaintiff clearly has an impairment. The regulations define impairment as “any physiological disorder or condition ... affecting one or more of the following body systems: neurological, mus-culoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genito-urinary, hemic and lymphatic, skin and endocrine.” 29 C.F.R. § 1630.2(h)(1). A heart disease, which by its nature affects the afflicted individual’s cardiovascular system, is an impairment for purposes of the ADA.
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Under § 1630.2, obesity generally is not a physical impairment, but it may qualify when it affects a bodily system and results from a physiological disorder.

Coleman v. Georgia Power Co. · filed 2000-02-09(h)(1), (j)

In light of the above, it appears to this court that while obesity generally is not considered an impairment it can be found to be an impairment in limited circumstances where it is shown both to affect one of the bodily systems outlined in the guideline definition for physical impairment and where such obesity is related to a physiological disorder. ... Although this court will not say that morbid obesity cannot be shown to be a physical impairment in some cases, having applied the above standard to the facts of this case, the court finds that Plaintiff has not met his burden of showing that his morbid obesity is a physical impairment as he has not shown that it is a “physiological disorder.”
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Section 1630.2(h) defines physical impairment to include a physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more bodily systems.

Sawinski v. Bill Currie Ford, Inc. · filed 1994-10-26(h)

“Disability” is defined under the ADA as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual....” 42 U.S.C. § 12102(2)(A). Physical impairment includes any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more bodily systems. 29 C.F.R. § 1630.2. Sawinski’s cranial disfigurement and deafness are physical impairments under this definition.
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Subsection (h) defines mental impairment as any mental or psychological disorder, including mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.

Fenton v. Pritchard Corp. · filed 1996-05-30(h)

The ADA regulations define mental impairment as “[a]ny mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.” 29 C.F.R. § 1630.2(h).
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Law changed since Same change as noted above.

Section 1630.2(j)(3)(i) provides that inability to perform a single, particular job does not substantially limit the major life activity of working; the impairment must significantly restrict the ability to perform a class or broad range of jobs.

Taylor v. Albertson's, Inc. · filed 1995-02-09(j)(3)(i)

Taylor’s inability to perform the specific job of selector does not constitute a substantial limitation in the major life activity of working. 29 C.F.R. § 1630.2(j)(3)(i).
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Section 1630.2(o)(2) recognizes reassignment to a vacant position as a possible reasonable accommodation for a qualified individual with a disability.

Gower v. Wrenn Handling, Inc. · filed 1995-02-17(o)(2)

As set out above, reasonable accommodation can include reassignment to a vacant position. 42 U.S.C. § 12111(9)(B); 29 C.F.R. 1630.2(o)(2)(ii). Here, Gower has established sufficient evidence that with “reasonable accommodation” he may have been “qualified” for the CSR position.
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The regulation recognizes reassignment to a vacant position as a possible reasonable accommodation when an employee cannot perform the essential functions of the current job.

Smith v. Midland Brake, Inc. · filed 1995-12-13(o)(2)(ii)

Where an employee is unable to perform the essential functions of his present job, “reasonable accommodation” may include reassignment of the employee to a vacant position. ... Nevertheless, because EEOC guidelines provide that reassignment to a vacant position is a potential reasonable accommodation, we shall examine whether the plaintiff has produced evidence sufficient to make a facial showing that he could have been accommodated by means of a transfer to a different job.
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Section 1630.2(h)(1) defines a physical impairment to include anatomical loss affecting the musculoskeletal system.

Needle v. Alling & Cory, Inc. · filed 2000-03-28(h)(1)

Given that the EEOC regards walking as a major life activity, and that an anatomical loss affecting the musculoskeletal system may be deemed a physical impairment, and viewing the facts in the light most favorable to plaintiff, I find for purposes of this motion that plaintiff was disabled within the meaning of the ADA.
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Section 1630.2(h)(1) includes infertility as a physiological disorder or condition affecting the reproductive system.

LaPorta v. Wal-Mart Stores, Inc. · filed 2001-05-22(h)(1)

Certainly, infertility also “affects” the reproductive system. By definition, a woman suffering from infertility has a diminished ability to become pregnant by natural means. ... The condition falls squarely within the regulation’s description of a “physiological disorder, or condition ... affecting [the] reproductive [system].” 29 C.F.R. § 1630.2(h)(1).
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Section 1630.2(h)(1) defines a physical impairment to include a physiological disorder or condition affecting the musculoskeletal system.

Lebron-Torres v. Whitehall Laboratories · filed 2001-05-30(h)(1)

Read most favorably to Lebrón, her evidence satisfies the first two requirements of this analysis. Her back condition was a physical impairment under the relevant EEOC definitions, being a "physiological disorder or condition" affecting the “musculoskeletal” system. See 29 C.F.R. § 1630.2(h)(1).
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(h)(1) defines impairment to include physiological disorders affecting the endocrine system, so thyroid disorders qualify.

Harris v. H & W Contracting Company · filed 1997-02-28(h)(1)

Therefore, disorders of the thyroid gland fit squarely within the meaning of impairment, as that term is defined by the applicable federal regulations.
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Section 1630.2(h)(1) defines an impairment to include a physiological disorder or condition affecting specified body systems.

Paleologos v. Rehab Consultants, Inc. · filed 1998-01-16(h)(1)

The applicable federal regulations define “impairment” to include “any physiological disorder, or condition ... affecting one or more of the following body systems: neurological, muscu-loskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genito-urinary, hemic and lymphatic, skin, and endocrine.” 29 C.F.R. § 1630.2(h)(1) (1996).
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Section 1630.2(h) excludes physical characteristics such as height or weight within the normal range, and those not resulting from a physiological disorder, from the definition of impairment.

Mehr v. Starwood Hotels & Resorts Worldwide, Inc. · filed 2003-07-23(h)

In Andrews v. Ohio, 104 F.3d 803 (6th Cir.1997), law enforcement officers who failed to meet newly instituted fitness standards because of either weight or cardiorespiratory endurance and strength, and who subsequently were subject to discipline, brought suit under the ADA. The officers alleged that even though they were not actually disabled due to being overweight and lacking in cardio-respiratory endurance and strength, the defendant perceived them to be. Id. at 806. This Court rejected that argument by first noting that under federal regulations, the term “impairment” does not include physical characteristics such as height or weight that are within the “normal” range. Id. at 808 (citing 29 C.F.R. § 1630.2(h) (App. 1995)). “Accordingly, physical characteristics that are ‘not the result of a physiological disorder’ are not considered ‘impairments’ for the purposes of determining either actual or perceived disability. ” Id. at 808 (emphasis added). Based on Andrews, Mehr’s disability discrimination claim is futile.
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Section 1630.2(h)(1) defines a physical or mental impairment to include a physiological disorder or condition affecting the cardiovascular system.

MacKenzie v. City & County of Denver · filed 2005-07-14(h)(1)

Therefore, jury could reasonably conclude, even without expert medical testimony, that MacKenzie had a condition affecting the cardiovascular system constituting a physical impairment under the ADA. See 29 C.F.R. § 1630.2(h)(1) ("Physical or mental impairment means: [ ] any physiological disorder, or condition...affecting one or more of the following body systems: . . . cardiovascular. . . .").
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Section 1630.2(h)(1) defines a physical impairment as a physiological disorder or condition, so obesity, including morbid obesity, qualifies only when it results from a physiological condition.

EEOC v. Watkins Motor Lines · filed 2006-09-12(h)(1)

The EEOC argues that morbid obesity is a “condition,” and that by this definition, a “condition,” unlike a “disorder,” need not have a physiological cause to be considered a physical impairment. Watkins counters that morbid obesity is only a physical impairment if it has a physiological cause. Although a literal reading of § 1630.2(h)(1) suggests that no physiological cause is needed, a closer look at the history of the regulation indicates that this interpretation is not correct. ... Thus, the best reading of § 1630.2 is that the comma following “disorder” is scrivener’s error, meaning that the statute requires a “physiological disorder or condition” in order for a “physical impairment” to exist under the ADA.
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Notes 601–750 of 4,244, oldest cases first.

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