In Valtierra v. Medtronic Inc, the Court ruled that obesity was not protected under the Americans with Disabilities Act (“ADA”). The plaintiff claimed that he was terminated from his employment due to his morbid obesity. He claimed that it was disability discrimination in violation of the ADA. The district court held that obesity was not a physical impairment, and could not constitute a disability, unless it was caused by an underlying physiological condition. Without providing that, plaintiff could not establish disability discrimination. The plaintiff appealed and the Court affirmed the district court’s grant of summary judgment in favor of the defendant. It agreed that it was not an impairment. Moreover, the Court also noted that even if plaintiff’s obesity was an impairment under the ADA, or he suffered from a disabling knee condition that the district court could have considered, he could not show a causal relationship between these impairments and his termination.
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