Ramsay v. National Board of Medical Examiners, No. 20-1058 (3d Cir. 2020)Annotate this Case
Ramsey, a medical student. unsuccessfully sought testing accommodations for dyslexia and ADHD from the National Board of Medical Examiners. Ramsey sued under the Americans with Disabilities Act. The Third Circuit affirmed the award of a preliminary injunction, requiring the Board to provide her accommodations. Ramsay established irreparable harm because she would likely be forced to withdraw from medical school if she could not take the initial test with accommodations and pass. The balance of equities tipped in her favor because granting her accommodations would not undermine the Board’s interests in fair and accurate testing and it was in the public interest for the ADA to be followed, to increase the number of physicians. Evidence that Ramsay’s reading, processing, and writing skills were abnormally low by multiple measures provided a sufficient comparison of her abilities to those of the general population to support the finding of disability. While the district court viewed Ramsay’s experts more favorably and found the Board’s experts unpersuasive, there is no indication that the court believed that it was compelled to defer to Ramsay’s experts; the court discounted the Board’s experts because they never met with Ramsay, engaged in too demanding an analysis of whether Ramsay had a disability, and overly focused on Ramsay’s academic achievements.