Ninth Circuit Considers Whether Morbid Obesity is a Disability Under the Americans with Disabilities Act

Plaintiff Jose Valtierra, a facility maintenance technician, sued his employer Medtronic, Inc. alleging that he was terminated on account of his disability, morbid obesity, in violation of the Americans with Disabilities Act (ADA).  Mr. Valtierra worked for Medtronic, Inc. for about ten years.  By the last year of his employment, he had gained 70 pounds, taken time off due to joint pain, and struggled to walk.  Mr. Valtierra’s supervisor, noticing that the employee was struggling to walk, allegedly became concerned about whether Mr. Valtierra was able to complete his work assignments.  When the supervisor checked the computer system, he discovered that Mr. Valtierra had falsified work records, so Medtronic, Inc. terminated him.

The district court looked at whether Mr. Valtierra suffered from a disability for purposes of the ADA and whether Medtronic’s termination was unlawful.  The district court granted Medtronic’s Motion for Summary Judgment, holding that morbid obesity is not a disability unless it is caused by an underlying physiological condition.  Since the court found that Mr. Valtierra was unable to point to an underlying physiological condition, there was no disability.  It dismissed the entire action.  Mr. Valtierra appealed the district court’s judgment. (Valtierra v. Medtronic, Inc. No. 17-15282, filed August 20, 2019).

Medtronic, Inc. defended the district court’s ruling and further provided the Mr. Valtierra was terminated because he falsified business records, which had nothing to do with his obesity.

The Ninth Circuit initially considered a broader definition of disability.  Under the ADA, a disability is defined as a “physical or mental impairment that substantially limits one or more major life activities.”  Thus, the Court reasoned it should look not only at whether Mr. Valtierra had an underlying physiological condition, but also whether he had an impairment that limited one or more major life activities.  However, the Ninth Circuit did not take a stand on the issue in this case.  The Court reasoned that Mr. Valtierra first had to demonstrate whether there was a causal relationship between Mr. Valtierra’s obesity or his knee conditions and his termination.  Mr. Valtierra was unable to do so because he admitted he had not completed his work assignments and falsified his records.  Further, Medtronic, Inc. had hired Mr. Valtierra when he weighed in excess of 300 pounds.  Thus, the Court reasoned there was no basis for concluding that he was terminated for any other reason than falsifying his work records.

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