James P. Smith was hired by Chrysler Corporation as an electrician and fired just a year later on grounds that he lied in his medical form that related to the job to the effect that he never suffered from a narcoleptic sleeping disorder. Smith then filed a suit at the district court alleging that the reason given for his sacking by his employer was only a pretext to mask unlawful discrimination perpetrated by his employer against persons with disability. He argued that Chrysler Corporation discriminated against him on the basis of his disability in violation of the American with Disabilities Act (ADA) and the Michigan Handicapper’s Civil Rights Act (MHCRA). Nonetheless, the district court gave a summary judgment in favor of his employer, Chrysler prompting Smith to appeal at the United States Court of Appeal Sixth Circuit which affirmed the finding of the district court.
Smith should have been fired for lying in his application for the job about his health condition. He failed to disclose that he suffered from a sleeping disorder whereas he knew very well that he had been treated for the same illness. It is immaterial that he was doing his job well. The main consideration in this respect is whether he was honest in his application which would have enabled his employer to make an informed decision. It must be distinguished that Chrysler did not discriminate against Smith for his disability as alleged by Smith. The false entry could have indicated to the company that he was a dishonest person who could not be trusted in his dealings with the employer. It is my submission that Chrysler may not have had any other reason for firing Smith besides the false entry made by Smith in his job-related application. Since it is alleged that Smith had been doing his job well and had no problems until this disclosure, it cannot be said that the employer sacked him for other unstated reasons.
Narcolepsy refers to a sleeping disorder characterized by recurrent and uncontrollable episodes of sleep that are usually associated with hallucinations, cataplexy and sleep paralysis. Persons afflicted with this condition have a sudden and uncontrollable lapse into a sleeplike state for a particular interval especially when their mind is not focused on a particular task. In order to answer the question as to whether narcolepsy should be considered as a form of disability under the American with Disability Act (ADA), it is imperative to examine the definition of disability in the Act. The ADA defines disability as a mental or physical disorder that substantially inhibits a significant life activity. It further goes on to prohibit discrimination by employers on the basis of disability. Since narcolepsy involves uncontrollable sleep, the same is sufficient to prove limit a major life activity in a substantial manner as to constitute disability under the ADA.
The legal judgment should not have gone against Chrysler for discriminating against Smith on the basis of disability. Though, it is correct that narcolepsy of which Smith was suffering from is a kind of disability, it is clear that he was not fired for being disabled but rather for failing to disclose such fact. Smith alleged that the reason proffered by his employer for sacking him was a pretext to mask its discrimination on grounds of disability. Just as the court found out, this cannot be correct. Chrysler acted in good faith belief that Smith had lied in his medical forms and this thereby protected the company from any liability. An employee can demonstrate discrimination on the part of the employer in two respects. One of the ways is by leading direct evidence that the employer stated that he fired him on the basis of his disability. This was not the case here and therefore this argument fails. The second way to prove discrimination and which Smith relied on is through indirect evidence of proving a prima facie case so as to create a mandatory presumption of discrimination on the part of the employer thus shifting the burden on him to disprove of such. This was similarly not proved by Smith and, therefore, his claim must fail.
After reading the case, several thoughts came to mind concerning the narcolepsy disorder and its relation to disability. I found out that narcolepsy leads to the relaxation of muscles, closing of eyes and uncontrollable sleep. Without doubt, such events have the effect of interfering with major life activities and thereby neatly fit into the definition of disability under the ADA.
Works Cited
Schall, Carol. M. "The Americans with Disabilities Act—Are We Keeping Our Promise? An Analysis of the Effect of the ADA on the Employment of Persons with Disabilities." Journal of Vocational Rehabilitation (2007): 191-203.
