Andrew Morgan v. Allison Crane & Rigging LLC, 114 F.4th 214

Andrew Morgan worked for Allison Crane & Rigging LLC as a millwright laborer and was terminated following a period of work restrictions due to a lower back injury.
In Fall 2020, Morgan’s chiropractor imposed, and the employer honored, light-duty restrictions for approximately 48 days while treating his back pain.
Morgan alleged ADA and PHRA violations for disability discrimination (both "actual" and "regarded as" disability), retaliation, and failure to accommodate, as well as a Pennsylvania common law wrongful discharge claim.
The District Court granted summary judgment to Allison Crane, holding Morgan’s conditions did not meet the standard for disability after relying on pre-ADAAA precedent and dismissed all his claims, including retaliation and accommodation, without specific analysis.
On appeal, the Third Circuit analyzed the impact of the ADA Amendments Act (ADAAA) on the definition of disability, clarified governing standards, and addressed each claim distinctly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether temporary back pain qualifies as an actual ADA disability	Morgan’s back pain and restrictions substantially limited major life activities	Duration was under six months and restrictions were minor; not a disability	Temporary impairments can qualify if substantially limiting; summary judgment reversed
Whether Morgan’s back pain could be "regarded as" a disability	Employer regarded him as disabled based on restrictions	Pain was both transitory and minor, so not covered	"Minor" was incorrectly assessed; this pain is more than minor—summary judgment reversed
Whether Morgan’s alleged herniated/bulged disc qualifies as a disability	Diagnosis and restrictions supported ADA disability	No admissible medical evidence of the diagnosis; expert evidence needed	Need for medical evidence affirmed; claim dismissed
Dismissal of retaliation/failure to accommodate claims	Claims supported by evidence and not addressed below	No argument by defendant; district court dismissed sua sponte	No justification for dismissal; vacated and remanded for further proceedings

Macfarlan v. Ivy Hill SNF, LLC, 675 F.3d 266 (3d Cir. 2012) (pre-ADAAA case cited by District Court, clarified as inapplicable post-ADAAA)
Eshleman v. Patrick Indus., Inc., 961 F.3d 242 (3d Cir. 2020) (discusses standards for "regarded as" and "actual" disability and the meaning of "minor")
Marinelli v. City of Erie, Pa., 216 F.3d 354 (3d Cir. 2000) (medical testimony not always required to establish disability, depends on condition complexity)
Colwell v. Rite Aid Corp., 602 F.3d 495 (3d Cir. 2010) (outlines summary judgment standards in ADA discrimination cases)
Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002) (pre-ADAAA, Supreme Court standard for disability, expressly abrogated by ADAAA)