Job Applicant’s ADA Privacy Claim Fails Because Defendant Was Not Her Employer

A former employee of an independent insurance agency in Pennsylvania that sold State Farm Insurance Co. products has no Americans with Disabilities Act breach of confidentiality claim against State Farm for informing prospective employers she has bipolar disorder, the U.S. District Court for the Western District of Pennsylvania ruled Aug. 13 (Sheriff v. State Farm Ins. Co., W.D. Pa., 3:12-cv-00243-KRG, 8/13/13).

Granting State Farm’s motion to dismiss Michelle Sheriff’s ADA complaint, the court said ADA provisions prohibiting the disclosure of confidential medical information apply only to employers and Sheriff acknowledged she was never employed by State Farm. ...