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Edwards v. Shelby County, Tennessee

The Case

Edwards v. Shelby Cnty., Tennessee,
No. 24-5730, — F.4th.
Sixth Circuit Court of Appeals,
November 7, 2025

Keywords

Americans with Disabilities Act (ADA), ADA Title I, asthma, disability, disability discrimination, employment discrimination, failure-to-accommodate, jury verdict, night blindness, reasonable accommodation, request for accommodation, retaliation, substantially limited.

Summary

Title I of the Americans with Disabilities Act (“ADA”) says an employer cannot discriminate against an employee based on their disability. The ADA also prohibits an employer from retaliating against an employee who has engaged in a protected activity—like asking for a reasonable accommodation. The ADA also lets an employee file a failure-to-accommodate claim, meaning the employer refused to provide an accommodation, even if the disability in question did not occur all the time.

Rebecca Edwards, a former Shelby County Tennessee Health Department employee sued the county under the ADA. Ms. Edwards claimed: (1) the County discriminated against her because of her night blindness; (2) the County retaliated against her when she asked for a schedule change due to her night blindness; and (3) the County failed to accommodate her asthma. The lower court jury agreed with Edwards on all three claims. The County appealed saying Edwards was not disabled under the ADA.

The Sixth Circuit Court of Appeals disagreed with the County. The court said that, under the ADA, the jury reasonably believed that Ms. Edwards’ night blindness made it hard for her to see at night, saying that seeing is a major life activity. The court also said that there was enough evidence for the jury to find that the County retaliated against Edwards for asking for an accommodation. The court added that the County also failed to accommodate Edwards’ asthma, even though it did not happen often.

The 6th Circuit agreed with the lower court and ruled in Edwards’ favor on all three ADA claims.

Facts of the Case

Rebecca Edwards was hired by the Shelby County Health Department as a COVID-19 contact tracer in July 2020. Five months later, she was promoted to be an Environmentalist Inspector, a job that required some night driving. Ms. Edwards’ night blindness made it hard for her to see at night. She said that bright headlights and streetlights made halos, made it hard for her to see lane lines and road signs, and affected her depth perception. She tried driving slowly and, at times, followed escorted vehicles like police cars when she had to drive at night.

In March 2021, the County changed its COVID inspection program and Ms. Edwards’ nighttime driving duties stopped. However, in August 2021, she was moved to a “Care Coordination Team”. She helped deliver food and groceries to people in COVID quarantine at an Econo Lodge motel.

Ms. Edwards believed the Econo Lodge was not safe, especially at night. She told about incidents that made her fearful. In one incident, a resident left drugs and drug paraphernalia in a room. In another incident a man who said he was a bounty hunter asked her to knock on a door for him. Ms. Edwards later emailed her supervisor about these safety concerns.

Ms. Edwards also had asthma, discovered after an episode that resulted in a visit to the emergency room. She disclosed her asthma when she was hired and said that she took medication that usually kept it under control.

In mid-September 2021, Ms. Edwards briefly could not get her medicine and experienced a serious flare-up of her asthma. She said she had a hard time breathing, could not sleep, and could barely walk from her bedroom to the bathroom. At 4:30 AM on September 15, 2021, she left a voicemail telling her supervisor that she was too sick to work that day. County policy only required employees to call thirty minutes before their shift. Ms. Edwards supervisor called her at 7:30 AM and told her to report to work because it was “too late” to cover her shift. Edwards, while still experiencing an asthma episode, went to work.

On October 4, 2021, Ms. Edwards was scheduled to take a solo shift from 3:00 PM to 11:00 PM at the Econo Lodge. She told her supervisor that she had night blindness, that she could not safely drive at night, and that she was afraid to work alone at the Econo Lodge late at night. Her supervisor told her she had driven in the past at night for her job. Edwards explained that her earlier nighttime drives were rare and usually involved escorts from police or coworkers.

On October 5, 2021, Edwards reported for the new night shift. At 4:07 PM, she emailed her supervisor and another manager, describing past criminal activity at the Econo Lodge and that it was not safe for her to work there alone at night. At trial, she testified that on that night, she saw a suspicious man and became scared and left work early.

Ms. Edwards did not know that earlier that day, before starting her new night shift job, her supervisor had asked that she be taken off her team. In response, Ms. Edwards’ supervisor was told to write down her concerns. The supervisor wrote a series of reports complaining that Ms. Edwards was sometimes late for work, sometimes refused to go to the Econo Lodge, left early, and did little work. Those reports also mentioned Edwards’ safety concern and her difficulty driving at night.

On October 6, 2021, Ms. Edwards’ schedule changed again, this time to 10:30 AM to 7:30 PM. She learned about the change at 10:45 AM – after the new shift had already started. Edwards reported to work after 1:00 PM and worked until 7:00 PM.

The next day, an administrator told Ms. Edwards’ supervisor to write down the schedule change and respond to Ms. Edwards’ complaints. At about the same time, the supervisor asked human resources if Ms. Edwards could be disciplined and maybe fired. The supervisor also got statements from coworkers saying that there was little crime at the Econo Lodge.

On October 8, 2021, human resources said Ms. Edwards should be fired for “insubordination,” “attendance,” and “falsification of information.” Ms. Edwards was fired on October 11, 2021. The written disciplinary form said that she had no prior disciplinary record. The form did not mention her night blindness or her request for a different schedule.

Ms. Edwards later filed a charge with the Tennessee Human Rights Commission, which was forwarded to the Equal Employment Opportunity Commission (EEOC). She eventually filed her lawsuit. After trial, a jury believed Ms. Edwards on her three ADA claims. The County appealed to the 6th Circuit.

Issues of the Case

  1. Is night blindness a disability under the ADA?
  2. Did Shelby County retaliate against Ms. Edwards by firing her because she asked for a reasonable accommodation related to her night blindness?
  3. Is Ms. Edwards’ asthma, even though it only happens sometimes, a disability under the ADA, and did Shelby County fail to reasonably accommodate that asthma when she was having a serious episode?

Arguments and Analysis

1. Is night blindness a disability under the ADA?

The County argued that night blindness was not a disability covered by the ADA. It had three points. First, it said that night blindness is not the kind of impairment that the ADA covers. Second, it argued that “driving,” especially driving at night, is not a “major life activity” under the ADA. Third, it said that Ms. Edwards did sometimes drive at night, including for work, to point out she was not “substantially limited” by the night blindness, as required by the ADA.

The court looked at the ADA’s definition of disability. A person has a disability if they have a physical or mental impairment that “substantially limits” one or more “major life activities.” The court said that a disability does not need to totally stop someone from doing an activity; it just needs to make that activity harder for that person than for the average person. The law lists many examples of “major life activities,” including seeing.

The court agreed that “driving” alone is not a major life activity. But the court saw Ms. Edwards’ issue was not about driving but her ability to see in low light. Seeing is a major life activity. The court said that night driving is just one of the many things that people do using their ability to see. The court also said that other federal courts had already ruled that serious night vision problems can substantially limit the major life activity of seeing, especially when those problems make night driving dangerous.

Next, the court looked at how Ms. Edwards’ night blindness affected her life. Edwards said that at night she had a hard time seeing traffic in her mirrors, reading road signs, and exits, and seeing barricades. She described how bright headlights made halos in her vision, and that going from bright to dark or dark to bright situations left her briefly unable to focus her eyes. She explained how after seeing headlights, she had trouble reading mail, watching television, or even looking at a restaurant menu. She also said that her night blindness had grown worse over time, and that it affected how her nervous system gets and interprets information from her eyes.

The County said that Edwards could still drive at night. But the court reasoned that under the ADA, someone can be disabled, even if they can still perform a task, so long as it takes a much greater effort, risk, or difficulty than most people. The key question was did Ms. Edwards night blindness substantially limited her ability to see at night compared with the general population?

The Court believed that Edwards’ night blindness substantially limited her ability to see in low-light conditions. But the court was careful to say that night blindness is not necessarily a disability for everyone. It depends on how severe it is and how it affects a person. In Ms. Edwards’ case, the court said that there was enough evidence that her night blindness was a disability under the ADA.

2. Did Shelby County retaliate against Ms. Edwards by firing her because she asked for a reasonable accommodation related to her night blindness?

The County disagreed with Ms. Edwards’ retaliation claim. To prove retaliation under the ADA, a person must show that they were engaged in protected activity (like asking for a reasonable accommodation in good faith), that the employer knew about it, that the employer took a negative action against her (like firing her), and that there was a connection between the two.

The County did not disagree that asking for an ADA accommodation was a protected activity. Instead, it argued Edwards’ request was not made “in good faith” because she was only afraid of crime at the Econo Lodge, not because of a disability. The County pointed to her October 5, 2021 email where she described past criminal activity at the Econo Lodge and said that it was unsafe for her to work there alone at night but did not talk about her night blindness. The County also pointed to the fact that Edwards left work early because she was afraid of a suspicious man.

The court agreed that the October 5, 2021 email focused on safety, not night blindness. But the court noted that this one email did not show the complete story. For example, on October 4, 2021 — the day before the email the County relied upon —Ms. Edwards told her supervisor directly that she had night blindness, that she could not safely drive home in the dark, and that the new 3:00 PM to 11:00 PM required night driving. Edwards also clarified that she had rarely driven at night in the past and usually with police escorts or coworkers.

When the court looked at the whole story, the record had both safety concerns at the motel, and medical concerns about Ms. Edwards’ night vision and ability to drive safely at night. The court explained that a request can still be protected under the ADA, even if the employee also has other, non-medical concerns. What matters is whether the employee, in good faith, is asking for a change to deal with a medical limitation.

The timing of Ms. Edwards’ requests is also important. Within a few days of Ms. Edwards’ raising these concerns and asking not to work nights, her supervisor started a paper record against her. Employees were also asked about Edwards’ behavior. Human resources was asked about termination, and she was fired. The discipline form that justified her firing said nothing about her disability-related complaints.

The court considered that Ms. Edwards told her supervisor about her night blindness and asked for a schedule change and the close timing between that request and her firing. The court ruled that the jury reasonably found that she made a good-faith request for accommodation and that the County retaliated against her for doing so.

3. Is Ms. Edwards’ asthma, even though it only happens sometimes, a disability under the ADA, and did Shelby County fail to reasonably accommodate that asthma when she was having a serious episode?

The County said that Edwards’ asthma was not a disability and that the County should not have to accommodate it. The court used the ADA’s “direct evidence” framework for a failure-to-accommodate case. Under the direct evidence approach, Ms. Edwards must show that: (1) she is disabled; (2) she is otherwise qualified for her job with or without a reasonable accommodation; and (3) she needed an accommodation that the employer refused to provide. The County focused on (1)—that Edwards was not disabled.

The County argued that because Ms. Edwards’ asthma was irregular, the court could not agree that she was disabled. It described Edwards’ asthma as mild, episodic, and usually controlled with medication. It said certain triggers made her have symptoms, that her condition was not always severe, and that the key incident in this case happened on a single day when she had run out of medicine.

The court disagreed with Shelby County for two reasons. First, the ADA says that conditions that come and go are disabilities if, when they are active, they substantially limit a major life activity. The ADA also says that courts should decide whether a disability is substantially limiting without thinking of the positive effects of medication or other aids. That means a court should consider how limiting the asthma is when it flares up, not how well it can be controlled when medicine is available and working.

Second, records showed that Edwards’ asthma flare-ups could be very serious. She testified that when her asthma is triggered, she has trouble breathing, cannot sleep, and sometimes cannot even walk short distances, such as from her bedroom to the bathroom. She explained that perfume or smoke typically bring on attacks and that she must rely on her rescue inhaler. She also described the severe September 2021 episode when, after being unable to fill her prescriptions, she was left gasping for breath and awake all night, leading her to call in sick.

The County also said that Edwards was not disabled by her asthma by pointing to another Sixth Circuit decision from 2008, Andrews v. Tri Star Sports and Entertainment Group. The court disagreed, saying that the plaintiff in that case lived a very active life, had a lot of intense exercise and activities, and could not provide specific examples where Andrews’ asthma made basic life activities significantly more difficult. The court noted that unlike Andrews, Ms. Edwards described times where her asthma seriously limited her breathing, sleep, and ability to walk even short distances. And, comparing Edwards’ case to the Andrews case, the court said that Ms. Edwards’ asthma substantially limited major life activities when it flared up and is considered a qualified disability under the ADA.

On the failure-to-accommodate question, the court noted that the key incident was the September 15, 2021 asthma flare-up. Ms. Edwards told her supervisor hours before her shift, explained that she could not easily breathe and had not slept, and she could not work. Instead of accepting this and changing the schedule, her supervisor told her to come in anyway. The court agreed that this proved the County refused to accommodate Edwards’ asthma. Additionally, the County did not show that letting Edwards stay home that day was an undue hardship, mainly because she provided more notice than County policy required.

Based on all the information, the court ruled that Ms. Edwards’ asthma was a disability that the County failed to reasonably accommodate.

Rulings

In this case, the Sixth Circuit agreed that Edwards’ night blindness substantially limited her ability to see at night and was a disability. It also agreed that the County retaliated against her for making a good-faith request for a reasonable accommodation related to night blindness, given she told her supervisor about her condition and was fired soon after.

The court further ruled that Edwards’ asthma, even though it did not happen very often and was usually managed with medication, could be a disability because, when it happens, it significantly limited major life activities such as breathing, walking, and sleeping. Finally, the court said that the evidence showed the County failed to reasonably accommodate Ms. Edwards’ asthma when it told her to come to work even though she had a serious flare-up that she had reported in advance.

Conclusion

Edwards v. Shelby County shows that conditions like night blindness can be a disability when it makes night-time seeing and driving more dangerous than it is for most people. When an employee honestly asks for help because of a disability, the employer must consider reasonable ways to accommodate that request. The employer cannot punish the employee for speaking up. Finally, asthma can be a disability even if it comes and goes, so long as, when it happens, it makes basic life functions like breathing, walking, and sleeping much harder.

Links to the Case

These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time.  In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.

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