Mattice v. Memorial Hospital of South Bend

Mattice v. Memorial Hospital of South Bend,
No. 3:98-CV-0303RM (N.D. Ind. Jan. 19, 2000)

Plaintiff, an anesthesiologist
at defendant hospital, was hospitalized and treated for a panic disorder and
major depression. He took a four-month medical leave of absence and then returned
to work without restrictions. In 1996 the plaintiff was suspended after a patient
died in the operating room while the plaintiff was supervising the anesthesia.
Following a peer review hearing, the Board agreed to lift the suspension conditioned
on monitoring and testing relating to the plaintiff’s mental health history.
Plaintiff claimed that these requirements made it impossible for him to resume
his duties and filed suit alleging disability discrimination in violation of
the Americans with Disabilities Act (ADA).

 

The court granted the defendant’s motion to
dismiss for failure to state a claim stating that in
order to state a claim, the plaintiff’s complaint
must contain “more than a mere assertion that
an employer regards an employee as substantially
limited in a major life activity. . . . To be
substantially limited in the major life activity of
working, one must be precluded from more than one
type of job, a specialized job, or a particular job
of choice.” The court held that the plaintiff’s
complaint was deficient because he failed to allege
that the hospital believed that he was
“substantially limited” in a major life
activity, that is, unable to work in a broad class
of jobs.