Sixth Circuit: Night Blindness Can Be a Disability Under ADA

The Sixth Circuit Court of Appeals affirmed a jury’s verdict in favor of a terminated employee, finding that the jury had reasonably concluded that her former employer had violated the Americans with Disabilities Act (ADA) by failing to accommodate her asthma condition, discriminating against her based on her night blindness, and retaliating against her for requesting an accommodation. Edwards v. Shelby Ctny., Tenn., No. 24-5730 (6th Cir. Nov. 7, 2025).

In July 2020, Rebecca Edwards was hired by Shelby County. On her employment application, she disclosed that she had asthma, but she did not disclose her night blindness, believing it did not fall within the categories on the application. In December 2020, she was promoted to a position that required nighttime driving. She drove at night despite her night blindness, sometimes with the support of coworkers. In August 2021, Rebecca was reassigned to a position requiring her to deliver groceries to individuals, many of whom were homeless, at a hotel where they were quarantined during COVID-19. She felt unsafe because she thought criminal activity was occurring at the hotel.

In September 2021, Rebecca had an asthma attack while she was at home. She left a voicemail message for her supervisor several hours before her shift, stating that she would not be able to come to work that day. Although she had notified the supervisor at least 30 minutes before her shift as required, the supervisor requested that she come in. In October 2021, the supervisor reassigned Rebecca to a 3 to 11 p.m. shift that would require her to drive 20 miles after dark to return home. Although she notified her supervisor of her night blindness and offered to obtain a doctor’s note, the supervisor dismissed her concerns. After starting the new shift, Rebecca emailed her supervisor to express her objection to the new shift and noted past criminal activity at the hotel.

Rebecca’s shift was soon changed from 10:30 a.m. to 7:30 p.m., but she was terminated several days later for insubordination, attendance issues, and falsification of information, despite no prior disciplinary record. Rebecca filed a lawsuit alleging that Shelby County had violated the ADA by failing to accommodate her asthma condition, discriminating against her based on her night blindness, and retaliating against her based on her request for an accommodation for her night blindness. A jury found in Rebecca’s favor on all three ADA claims. The federal district court denied Shelby County’s motion for judgment as a matter of law, and it appealed.

In a de novo review, the Sixth Circuit Court of Appeals evaluated the sufficiency of the evidence for each claim. The court rejected Shelby County’s assertion that the jury had erred in finding that Rebecca was disabled with respect to her disability discrimination claim. The court determined that, because the definition of disability must be interpreted to favor broad coverage under the ADA, and an impairment was not required to significantly or severely restrict a major life activity to qualify as substantially limiting, night blindness could be a substantial limitation. Further, because limitations on night vision are strong evidence of a substantial impairment to the major life activity of seeing, the jury did not err in finding that Rebecca’s night blindness was a disability. The fact that Rebecca sometimes drove at night did not preclude a finding that she was substantially limited in the major life activity of seeing.

The court also found that the jury could reasonably conclude that Rebecca had made a good-faith request for reasonable accommodation for her night blindness in relation to her retaliation claim. Although she expressed concern for her safety due to criminal activity at the hotel in an email to her supervisor after her reassignment to a night shift, she also informed her supervisor in person that she did not want the night shift because of her night blindness and difficulties seeing and driving at night.

In addition, the court determined that the jury had reasonably concluded that Rebecca’s asthma was a disability and that Shelby County had violated the ADA in failing to accommodate it. The fact that her asthma was not continuously symptomatic and was typically manageable with medication did not preclude it from being an impairment that substantially limited major life activities such as breathing, sleeping, and walking.

Accordingly, the court affirmed the trial court’s judgment in favor of Rebecca on her ADA claims.

Read the full opinion.