South-Western Legal Studies in Business

Morbid Obesity Not an ADA-Protected Disability Unless Physiological
Description

Appeals court held that an employer was not liable under the ADA for dismissing an obese employee. The weight affected his ability to perform his job. Morbid obesity is not a disability unless it is physiological in origin.

Topic

Employment Discrimination

Key Words

Disability; Morbid Obesity

C A S E   S U M M A R Y
Facts

Grindle was hired by Watkins Motor Lines as a driver and dock worker. More than half his time was spend loading and unloading freight. When hired, he weighed 345 pounds. Over the next five years his weight ranged as high as 450 pounds. When climbing a ladder at work, a rung broke and he suffered a knee injury. The company allowed him to take 180 days leave to try to recover from the injury. At the end of that time, his doctor said he could return to work, but Grindle said he could not. Another doctor, noting that he weighed 405 pounds, held that he could not safely perform the requirements of the job because of his weight. Grindle was fired and filed a complaint with the EEOC. The EEOC sued Watkins on his behalf, contending the company violated the ADA by discriminating against Watkins because of his weight. The district court held for Watkins. The EEOC appealed.

Decision

Affirmed. Grindle's weight was not an impairment under the ADA since there was no physiological cause for his morbid obesity. If a physical characteristic is not an ADA impairment, an employer is permitted to prefer one physical characteristic over another.

Citation

EEOC v. Watkins Motor Lines, Inc., 463 F.3d 436 (6th Cir., 2006)

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