D.C. Circuit on Definition of Disability

The D.C. Circuit issued this opinion involving the ADA's definition of disability. As the court viewed the record, the case involved a person who had some kind of itching reaction to something at his workplace. The itching reaction would last long after the plaintiff got home at night and therefore make it impossible for him to get a good night's sleep. The court held that the plaintiff had not raised a genuine issue of fact regarding whether he experienced a substantial limitation in (what the court assumed to be) the major life activity of sleeping, because he was limited in sleeping only if he continued to work in his current job. Although the plaintiff had itching reactions in other locations, he presented no evidence that the itching reactions he experienced outside of his workplace were severe enough to make him lose sleep. Thus, if he worked in another job, there's no reason to think he'd be limited in sleeping. This decision is very similar to the Supreme Court's decision in Toyota in that it bars an ADA plaintiff from invoking a non-work major life activity to get around Sutton's restrictive reading of the concept of substantial limitation in the major life activity of working.