Discovery Attorney’s Insomnia Not Grounds For ADA, FMLA Claims, Fourth Circuit Says

A lawyer who worked for Discovery Communications LLC in Maryland failed to show insomnia she experienced in 2006 rendered her disabled for purposes of the Americans with Disabilities Act, the U.S. Court of Appeals for the Fourth Circuit ruled April 5 (Anderson v. Discovery Commc’ns LLC, 4th Cir., 11-2195, 4/5/13).

Affirming a lower court’s grant of summary judgment against Victoria Anderson on her disability discrimination claims, the appeals court found that under the pre-amendment ADA, Anderson needed to establish she was substantially limited in the major life activity of sleeping to demonstrate she was a “qualified individual ...