Weaving v. City of Hillsboro

A person is not covered under the Americans with Disabilities Act simply because they lack interpersonal skills.

Matthew Weaving was diagnosed at the age of six with “hyperkinetic activity” or more commonly known today as ADHD. He was prescribed medication to treat it, but stopped exhibiting the symptoms at the age of twelve and was taken off of the medication. He continued to experience interpersonal problems throughout his childhood and into his adulthood. When he joined Beaverton Police Department (“BPD”), he did not mention the ADHD diagnosis since he no longer exhibited the symptoms. During his employment at BPD, his evaluations indicated that he had difficulty working with others in a team environment. Throughout his career, there were conflicting evaluations of Weaving and his work. There were several grievances filed against him and eventually Weaving acknowledged that the source of these problems stemmed back to his childhood diagnosis of ADHD. Eventually, Weaving was terminated from his employment. Weaving filed a claim in federal district court under the Americans with Disabilities Act (“ADA”) alleging that he was fired because of his disability. The district court found that Weaving was fired becasue of his disability. On appeal, the panel found that throughout Weaving’s career, he was praised for his competence as an officer and was deemed capable of doing the work however he merely lacked the interpersonal skills that were expected from individuals in this line of work. The panel found that Weaving’s lack of interpersonal skills “did not amount to a substantial impairment of his ability to interact with others.” Because of these findings, the panel determined that a jury could not find as a matter of law that his ADHD affected his ability to work within the meaning of the ADA. REVERSED and REMANDED.