Opinion

Haynes, Charles v. Williams, Anthony

  • 392 F.3d 478
  • 364 U.S. App. D.C. 108
  • 16 Am. Disabilities Cas. (BNA) 462
  • 2004 U.S. App. LEXIS 26276
  • 2004 WL 2913246
Court
Court of Appeals for the D.C. Circuit
Filed
Dec 17, 2004
Status
Published
Author
Williams
On the bench
Edwards, Garland, Williams
Cited by
99 cases

reasoning that because "sleep needs vary radically,” "the only way to answer the question whether the impairment 'substantially' limit[s] [a plaintiff’s] sleep would be by reference to the effect on his waking 'life activities’ ” without looking separately at the intermediate step of an impact on sleep

How later courts described this case

  • reasoning that because "sleep needs vary radically,” "the only way to answer the question whether the impairment 'substantially' limit[s] [a plaintiff’s] sleep would be by reference to the effect on his waking 'life activities’ ” without looking separately at the intermediate step of an impact on sleep
  • holding that to succeed, a plaintiff must prove that her employer believed she had a physical impairment that substantially limited one or more major life activities
  • suggesting that “the only way to answer the question whether the impairment substantially limit[s] [a plaintiffj’s sleep would be by reference to the effects on his waking life activities” (internal quotation marks omitted)
  • affirming district court’s grant of summary judgment to employer because plaintiffs “evidence would not have permitted a reasonable jury to conclude that [he] was substantially limited in a major life activity”

Written by the judges who cited it.

The opinion

STEPHEN F. WILLIAMS, Senior Circuit Judge,

concurring.

I write separately only to question the premise, assumed by all parties (and thus quite properly not ruled on by the court), that “sleeping” is “a major life activit[y]” for purposes of the Americans with Disabilities Act, specifically 42 U.S.C. § 12102 (2)(A). Here no analytical problem arises, because Haynes loses for want of evidence that his impairment, idiopathic pruritus, caused his sleeplessness. But had he prevailed on that question, the next issue would have been whether the impairment “substantially” limited his sleeping. See id. Not only is sleep largely an instrumental activity — valued for its ability to refresh us for various waking activities — but humans’ sleep needs vary radically. Some can be successful chief executives of firms — -or countries — on very little sleep, while others require a full eight *486 hours, or more, to get through only moderately productive days. See, e.g., Only Wimps Need 8 Hours, L.A. Times, Feb. 10, 1994, at 1 (“Winston Churchill slept little and sometimes ridiculed those who slept more.”). Thus the only way to answer the question whether the impairment “substantially” limited Haynes’s sleep would be by reference to the effects on his waking “life activities.” A more direct answer to that question would look straight to the waking activities adversely affected. The intermediate step seems to add nothing useful.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.