In Robinson v. Morgan Stanley Dean Witter, a federal court in Illinois held that an employee with "extremely high sensitivity" to perfumes and other fragrances did not have a claim under the Americans with Disabilities Act (ADA). The plaintiff complained that she was allergic to perfumes and other fragrances, which caused her to suffer cold-like symptoms lasting from a few hours to a week, including headache, stuffiness, fatigue, sore throat, and shortness of breath. The court found that plaintiff's condition did not render her substantially limited in her performance of any major life activity. Furthermore, the court found that the employer took reasonable steps to accommodate plaintiff's alleged disability as it provided plaintiff with several accommodations, including special seating arrangements, the use of a fragrance-free rental car, intervention with specific employees that wore fragrances, and a department-wide memorandum from management encouraging employees to be considerate of individuals with sensitivity to fragrances and perfumes.