Booth v. Nissan North America, Inc., No. 18-5985 (6th Cir. 2019)Annotate this Case
After Booth started working at a Tennessee Nissan factory, he injured his neck and sought medical treatment. Booth’s physician recommended several work restrictions, including that he not reach above his head or flex his neck too much. Booth. continued to work on the assembly line for about a decade without incident. In 2015, Booth requested a transfer to another position in the factory, which Nissan denied because that position’s duties conflicted with Booth’s work restrictions. Booth claimed that Nissan’s denial was disability discrimination that violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101. Nissan then announced plans to restructure the assembly line. Booth alleged that two additional jobs Nissan assigned to him as part of the restructuring would have violated his work restrictions, When he informed Nissan about this conflict, Nissan told him to see a physician. Booth’s physician modified the restrictions, clearing him to work the new jobs. Although Booth remains a Nissan employee, he claimed that Nissan failed to accommodate him—a separate ADA violation—by pressuring him to remove his work restrictions. The Sixth Circuit affirmed summary judgment in favor of Nissan. To sue under the ADA, the plaintiff must be disabled; just because a plaintiff has work restrictions does not mean that he is disabled. Booth has not advanced evidence that he is disabled.