## Facts

- Stacy L. Deane worked as a registered nurse for Pocono Medical Center (PMC).
- Deane suffered a work-related injury that limited her ability to do heavy lifting.
- Deane asserted she could continue nursing work if heavy-lifting tasks were limited or reassigned and other assistance or task restructuring was provided.
- PMC concluded Deane could not perform required duties and terminated her employment.
- Deane sued under the ADA, alleging PMC regarded her as disabled and failed to accommodate her.
- The district court granted summary judgment for PMC; a Third Circuit panel affirmed using an “all functions” approach for “regarded as” plaintiffs.
- The Third Circuit reheard the case en banc to determine the proper “qualified individual” standard for “regarded as” claims and whether summary judgment was appropriate.

## Issues

1. Whether an ADA plaintiff proceeding under a “regarded as” theory must prove she can perform all job functions, or only the essential functions, with or without reasonable accommodation, to be a “qualified individual.”
2. Whether the summary-judgment record created genuine disputes of material fact as to (a) whether PMC regarded Deane as disabled and (b) whether heavy lifting was an essential function of Deane’s nursing position and could be addressed by reasonable accommodation.

## Decision

- The en banc court rejected the “all functions” standard and held that the ADA requires proof only that the plaintiff can perform the position’s essential functions, with or without reasonable accommodation.
- The court held this essential-functions standard applies equally to “regarded as” plaintiffs.
- The court concluded Deane presented sufficient evidence to create genuine disputes about whether PMC misperceived her as disabled and whether heavy lifting was an essential function of her job (and whether accommodations could allow performance of essential functions).
- The court vacated the summary judgment for PMC and remanded for further proceedings.

## Legal Principles

- Under the ADA, a “qualified individual with a disability” is one who can perform the essential functions of the position, with or without reasonable accommodation.
- The “qualified individual” inquiry focuses on essential functions, not every listed or marginal task.
- The ADA’s “regarded as” coverage protects individuals subjected to adverse action based on an employer’s mistaken beliefs about disability; courts should not impose a stricter qualification standard on such plaintiffs than on plaintiffs with actual disabilities.
- Summary judgment is improper where evidence permits a reasonable factfinder to dispute (a) whether the employer regarded the employee as substantially limited in working and (b) whether the contested duty is truly essential and can be addressed through reasonable accommodation.

## Conclusion

The Third Circuit held that ADA plaintiffs alleging they were regarded as disabled need only show they can perform the essential functions of the job with or without reasonable accommodation, and it remanded because factual disputes about the employer’s perception and the essential nature of heavy lifting precluded summary judgment.


Deane v. Pocono Med. Ctr., 142 F.3d 138 (3d Cir. 1998) (en banc)