Is Social Anxiety Disorder a Disability Covered by the ADA?

"Yes" appears to be the answer, according to a recent ruling by the United States Court of Appeals for the Fourth Circuit in the case Jacobs v. North Carolina Court System. While the decision is technically binding only in the states of the Fourth Circuit, North Carolina, South Carolina, Virginia, West Virginia and Maryland, it almost surely would be followed by other courts including those in Kentucky.  

Christina Jacobs was hired on as a deputy courthouse clerk at the New Hanover County courthouse in North Carolina.  She was a good employee and was assigned to the front desk in the clerk's office, a job that caused her to have direct and frequent contact with lawyers and other individuals that did business daily with the clerk's office.  She told her bosses about her diagnosis of social anxiety disorder and requested that she be assigned to other duties in the clerk's office (it was a pretty large office with about 30 employees).  Her request for a reassignment was a request for a reasonable accomodation.

The employer, the North Carolina court system, asserted as a defense that "social anxiety disorder" was not a disability covered by the ADA, which, if true, meant it had no duty to consider let alone grant Jacobs' request.  The Court rejected this argument and ruled that "social anxiety disorder" was a disability covered by the Americans With Disabilities Act (ADA).  

There is a two-step process to determining whether a condition is a "disability" under the ADA: (1) whether it affects a major life activity; and, (2) if it does affect a major life activity, whether it substantially limits the person's ability to perform or engage in the activity.

Jacobs' case was easy on the first point, since, as the Court pointed out, "Few activities are more central to the human condition than interacting with others." As to the second, the Court ruled that Jacobs did not have to prove that she could function only as a hermit.