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A migraine creates an intense, throbbing pain that can be debilitating. An employee suffering from a migraine may have their job performance affected or be forced to miss work altogether. While medical research has not pinpointed an exact cause of migraines, stress can contribute to the frequency and severity of headaches. So, is a stress migraine a disability as defined by the Americans with Disabilities Act?
The Second Circuit Court of Appeals said no, at least when the employee suffering from migraines did not show he was prevented from performing a broad range of jobs or within a class of work. A migraine caused by a specific job is not a disability.
Ronald Woolf began working at Bloomberg, L.P., as a sales consultant but soon started to get migraines, which Woolf claims were a result of job stress. Woolf began receiving poor performance reviews, which increased his anxiety and the frequency of migraines. Ultimately, he took medical leave. Upon his return he was terminated for poor performance. Woolf sued for violation of the ADA.
The question for the Second Circuit was whether Woolf's migraines constituted a disability as defined by the ADA Amendments Act of 2008. The ADA itself defines a disability as "a physical or mental impairment that substantially limits one or more major life activities." While the Second Circuit panel noted that Wolf's migraines "arguably" affected his performance, the panel was unconvinced that this impairment – which was not disputed – prevented him from working anywhere else.
In support of this position, the panel noted that Woolf had asked his employer to transfer him to another part of the company, or at least transfer him to new supervisors. Presumably, this would have reduced stress and his migraines, allowing him to focus more on his work.
Extensive precedent exists that under the ADA, if a plaintiff's disability only limits a single, specific job, then it is not an impairment to working, and not a disability as defined by the ADA. However, these precedents mostly occurred before the 2008 Amendment to the ADA. Woolf argued that the Amendment, which was passed in response to the Supreme Court's narrow interpretation of disability, also threw this long-standing precedent into doubt.
The panel disagreed, however, with the Per Curiam opinion noting that "nothing in the ADAAA's text, or its legislative history for that matter, suggests that Congress intended to modify, let alone abandon altogether, the well‐established understanding" that a medical condition that only affects a specific job is not a disability.