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Bipolar Worker's Firing Didn't Violate Disability Law

A Kentucky university that fired an employee with bipolar disorder after an outburst at work did not violate disability discrimination law because there was a legitimate business reason for the decision, a federal judge has ruled.

U.S. District Judge John Heyburn found that plaintiff Crystal Snyder failed to show she is disabled under state or federal definitions of the term. The judge determined instead that she was properly fired for violating work rules at Sullivan University.

According to Snyder's complaint, she worked in the accounts receivable/customer service department at the Louisville school.

She has received treatment and medication for psychological illness since 1994 and was diagnosed with bipolar disorder in 2004, the complaint said. Snyder said she told her supervisors about her illness.

The incident that led to Snyder's firing took place in August 2005. Snyder said she reacted with a "verbal outburst" when another employee left a binder in her work area. She admitted that she raised her voice and leaned over the employee's desk when the co-worker "yelled back stuff," according to the court's opinion.

Snyder's supervisor witnessed the incident and reported the details to her own supervisor. After meeting with Snyder two days after the "outburst," the two supervisors fired her for "unacceptable" and "inappropriate" behavior.

Snyder sued Sullivan the U.S. District Court for the Western District of Kentucky, alleging her termination violated the Americans with Disabilities Act and the Kentucky Civil Rights Act.

Judge Heyburn granted the university's motion for summary judgment.

First, he noted that both the ADA and the KCRA define a disability as a physical impairment that "substantially limits one or more major life activities," such as walking, performing manual tasks or caring for oneself.

The laws say a person is "disabled" if she has a record of impairment or is regarded as having an impairment, according to the judge.

He rejected Snyder's argument that a 1993 suicide attempt and two other depression-related episodes are evidence that she cannot care for herself.

"Three particularly acute episodes over the course of 14 years do not permit the inference of any substantial residual limitation that restricts Snyder's ability to care for herself as would the average person," Judge Heyburn said.

"Snyder has not offered evidence that her disorder prevents her from completing household tasks or other activities of central importance to her daily life," he added.

Snyder also had argued that Sullivan "regarded her" as disabled in violation of state and federal disability law.

She maintained that the university mistakenly believed that her bipolar disorder substantially limited her ability to work and led it to "distort a routine disagreement with a co-worker into an extreme and outrageous act," the opinion says.

Judge Heyburn said there was no testimony suggesting that, as required by the state and federal disability statutes, Snyder was unable to work in a substantial number of jobs, not just her job at the university.

In addition, he found no evidence that Sullivan relied on stereotypes, rather than Snyder's doctor's opinion, to conclude that she was unable to work.

Finally, Judge Heyburn said a supervisor's testimony about Snyder's "combative" mood and attitude "cannot be stretched to suggest that Sullivan regarded Snyder as 'unable to work' because of her bipolar disorder."

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