# Haynes, Charles v. Williams, Anthony

> Court of Appeals for the D.C. Circuit · December 17, 2004 · 392 F.3d 478

URL: https://www.frixlaw.com/law-library/cases/9439414

## Case

- **Full name:** Charles HAYNES, Appellant v. Anthony A. WILLIAMS, Mayor, District of Columbia and District of Columbia, Office of Chief Financial Officer, Appellees
- **Court:** Court of Appeals for the D.C. Circuit
- **Decided:** December 17, 2004
- **Citations:** 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
- **Precedential status:** Published
- **Opinion:** Concurrence by Williams
- **Judges:** Edwards, Garland, Williams
- **Cited by:** 99 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9439414

## How later opinions describe it (automated extraction)

- 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 …
- 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
- 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”
- observing that the plaintiff had conceded that if “the symptoms of an impairment are brought on by a single workplace, such an impairment is not substantially limiting within the meaning of the ADA”

## Opinion text

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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9439414. Public record. Not legal advice.