A Federal District Court recently ruled that an employee unable to work at a perfume manufacturing plant because of migraine headaches did not have a valid claim under the Americans with Disabilities Act (ADA).

In Thomas v. Avon Prods., Inc., S.D. Ohio, No.1:05cv794 (6/20/07), a discharged employee claimed that migraine headaches caused by chemical exposure at work prevented her from working in any work environment with “perfumed ambiance,” rendering her disabled. The Court, however, ruled that this was not enough because her medical condition only disqualified her from a small number of jobs, not most jobs or “a broad range of jobs in various classes.” Accordingly, although the plaintiff may be limited in the number of jobs she could perform, she was “not substantially limited in a major life activity.” Without such a “substantial” limitation, she was not disabled under the ADA.