Doyal v. Oklahoma Heart, Inc.

213 F.3d 492 (2000)

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Doyal v. Oklahoma Heart, Inc.

United States Court of Appeals for the Tenth Circuit
213 F.3d 492 (2000)

  • Written by Arlyn Katen, JD

Facts

Carol Doyal (plaintiff) began working at Oklahoma Heart, Inc. (OHI) (defendant), a cardiology practice group, in 1992. By 1995, Doyal was OHI’s business office manager. In early 1995, Doyal began feeling helpless, anxious, stressed, and unmotivated. Doyal experienced difficulties thinking clearly, learning, remembering, and interacting with others. Doyal lost interest in work and everyday life activities. Doyal developed insomnia, often sleeping less than three hours each night, and began experiencing panic attacks. Ultimately, in March 1995, Doyal had a mental breakdown at work and her supervisor told her to take a week off. During her week off, Doyal was diagnosed with a type of depression. After Doyal requested a less-stressful position, OHI transferred Doyal to the position of human-resources director and reduced her salary. Although Doyal began taking an antidepressant that she found to be extremely helpful, Doyal was briefly hospitalized for a stress-related illness in April 1995. Doyal struggled as a human-resources director, and OHI terminated Doyal in May 1995. OHI cited several reasons for terminating Doyal, including (1) her inability to make decisions; (2) her frequent forgetfulness of job candidates’ names and qualifications; and (3) her breach of patient confidentiality, which occurred because she threw away medical records, mistakenly believing that a doctor had given her permission to do so. Doyal sued OHI in federal district court, arguing that OHI had violated the Americans with Disabilities Act (ADA) by terminating her. Doyal stated that her depression was a disability that limited her ability to learn, sleep, think, and interact with others. Specifically, Doyal claimed that she had difficulties learning names and learning OHI’s new computer system. In the alternative, Doyal argued that OHI perceived Doyal as disabled. The district court granted OHI’s motion for summary judgment, dismissing Doyal’s claim. Doyal appealed.

Rule of Law

Issue

Holding and Reasoning (Alarcón, J.)

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