Marinelli v. City of Erie

City worker who suffered residual medical difficulties resulting from earlier work related arm injury failed to submit evidence to support, as a matter of law, ADA claim that he was substantially limited in a major life activity.

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The full case caption appears at the end of this opinion.

At the time of its passage, many rightfully hailed theAmericans with Disabilities Act (ADA) as comprehensivecivil rights legislation. See, e.g., Statement by PresidentGeorge Bush upon Signing S.933, 26 WEEKLY COMP. PRES.DOC. 1165 (July 30, 1990) (stating that the ADA “promisesto open up all aspects of American life to individuals withdisabilities”). Notwithstanding its comprehensive nature,however, the ADA’s employment provisions specifically limitits protections to those individuals who can establish thatthey are indeed “disabled.” Upon the ADA’s promulgation,both the House and the Senate stipulated that Congressdid not intend the ADA to protect those who suffered from”minor, trivial impairments”; to the contrary, an individualis only “disabled” under the auspices of the ADA if his”important life activities are restricted as to the conditions,manner, or duration under which they can be performed incomparison to most people.” H.R. REP. NO. 101-485, at 52(1990); S. Rep. No. 101-116, at 23 (1989).

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Marinelli v. City of Erie

City worker who suffered residual medical difficulties resulting from earlier work related arm injury failed to submit evidence to support, as a matter of law, ADA claim that he was substantially limited in a major life activity.

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