Boitnott v. Corning Inc., No. 10-1769
Decided Feb. 10, 2012
Michael R. Boitnott brought a claim against his employer, Corning Incorporated under the Americans with Disabilities Act, asserting that his inability to work more than eight hours per day and rotate day/night shifts as a result of physical impairment rendered him disabled under the ADA. Boitnott alleged that Corning violated the ADA by failing to provide him a reasonable accommodation for his disability. Corning contended that because Boitnott was physically able to work a normal forty hour work week and he had not demonstrated that his impairments significantly restricted the class of jobs available to him, he could not establish that he had a “substantial” limitation upon which to base a claim of disability under the ADA. The Fourth Circuit affirmed the district court’s grant of summary judgment for Corning. To be a covered disability, the disability must substantially limit a major life activity. Being able to work overtime does not substantially limit the major life activity of working. Therefore, Boitnott’s inability to work overtime did not mean that he was disabled under the ADA.
-Sara I. Salehi