accommodation

Employment discrimination cases under the Americans with Disabilities Act (“ADA”) often turn on whether the employee’s medical condition qualifies as a disability under the statute. While some medical conditions clearly fall within the statute, others remain legally unsettled. In the case of Proffitt v. North Carolina Department of Public Safety, No. 5:23-CV-00306 (E.D.N.C. July 25, 2025) a federal Court faced an unsettled question regarding severe menstrual pain and endometriosis constituting a disability under the ADA. The Court found that these medical conditions can qualify as disabilities in certain circumstances.

By way of background, Plaintiff Christian Proffitt had experienced painful menstrual cycles since middle school. She claimed that the pain on the first day of her cycle each month was so severe that she was confined to her bed. For more than a decade, she managed her pain with 800 milligrams of ibuprofen. Thereafter, her doctor prescribed various opioids for her pain. In March 2024, Proffitt received a formal diagnosis of endometriosis.

Proffitt, began working for North Carolina Department of Public Safety (NCDPS) in December 2020 as a Juvenile Court Counselor (JCC) trainee. The JCC training program lasts 12–24 months, and successful trainees may be promoted to permanent positions.

In April 2022, Proffitt went to the emergency room due to pain from her menstrual cycle and missed two or three days of work. She provided her supervisor with a doctor’s note. On May 6, 2022, Proffitt spoke with her supervisor by phone about two medical issues, including her heavy menstrual cycles and painful cramps. She explained that she might need to work from home for one day each month. Endometriosis was also discussed, although Proffitt did not have a formal diagnosis at this time. During this conversation, Proffitt’s supervisor allegedly criticized the amount of medical leave she had taken from work, stating that she had used an excessive amount of time off and that this reflected poor work ethic.

On May 12, 2022, Proffitt, her supervisor, and the Court Counselor Chief met to discuss concerns about Proffitt’s work performance. During the meeting, Proffitt again mentioned that she might need to work from home due to her menstrual pain. The Court Counselor Chief denied the request, stating that if he allowed her to work from home, he would have to allow every woman in the office to do the same. Proffitt claims that during this meeting she was told she would not be promoted and would be terminated at the end of her training period. NCDPS disputes that this was said. That same day, Proffitt submitted her resignation.

Proffitt then filed a lawsuit against NCDPS asserting several legal claims, including a claim that NCDPS violated her rights under the ADA. The parties then filed summary judgment motions against each other. Within their motions the parties disputed, among other things, whether Proffitt was considered disabled under the ADA.

The Court analyzed whether Proffitt’s painful menstrual cycles constituted a disability under the ADA, meaning whether it qualified as an impairment that substantially limited one or more major life activities. To demonstrate the severity of her condition, Proffitt relied on several types of evidence. She submitted online posts in which she described her debilitating symptoms and their impact on her daily life. She testified that she had missed college classes because of her cramps, and that the pain caused her to vomit and lie paralyzed in bed for an entire day. She also submitted doctors’ notes documenting that her painful menstrual cycle caused her to miss work.

Although federal courts have historically been divided on whether endometriosis qualifies as a disability under the ADA, the U.S. District Court for the Eastern District of North Carolina concluded that Proffitt had presented sufficient evidence that her endometriosis substantially limited her major life activities. Specifically, having to be bedridden at least one day a month with pain and vomiting, interfered with her ability to engage in multiple major life activities. As a result, Proffitt’s ADA claim survived summary judgment and was allowed to proceed. The case ultimately settled.

The key takeaway from this case is that determining whether someone is disabled under the ADA is a complex and fact-specific issue. When an employee reports a medical condition and requests an accommodation, management should avoid responding with an immediate “no” even if the condition initially appears mild. Each accommodation request must be evaluated carefully, with attention to the individual’s specific circumstances, before a decision is made as to how to respond.