Tenth Circuit Rules Hostile Environment Claims Are Actionable Under the ADA

Yesterday, in Lanman v. Johnson County, 2004 WL 3017258 (available for free on the web here), the Tenth Circuit expressly ruled that hostile work environment claims may be brought under Title I of the ADA. That ruling is in line with the holdings of the other circuits to have addressed the question. (On the merits, not surprisingly, the court ruled that the plaintiff -- who had alleged that her employer and co-workers regarded her as having a psychiatric impairment -- did not satisfy the ADA's definition of disability.)