In Beaton v. Metropolitan Transportation Authority, the Southern District of New York denied a motion filed by the Metropolitan Transportation Authority (“MTA”) to dismiss Earl Beaton’s disability discrimination claims under the American with Disabilities Act (“ADA”) and New York City Human Rights Law (“NYCHRL”), including wrongful termination, failure to provide a reasonable accommodation, and retaliation claims. Beaton had appeared to be sleeping on the job because his schizophrenia medication caused his eyes to close. The MTA immediately suspended and then terminated his employment, despite having knowledge of his disability. Beaton maintained that “his disability was the cause of his termination.”
Beaton was diagnosed with schizophrenia in 1985. Schizophrenia is a chronic and severe mental disorder that affects how a person thinks, feels, and behaves. Although schizophrenia is not as common as other mental disorders and the symptoms can be very disabling, it can be treated with the right medications. Beaton’s symptoms included depression, anxiety, paranoia, mental instability, auditory hallucinations, and the belief that other people can read his mind. As a result, Beaton’s schizophrenia impairs his ability to work, think, communicate, sleep, learn, focus, concentrate, and remain awake. Beaton received psychiatric care since his diagnosis and has been successful in treating his mental condition with antipsychotic medication. Specifically, Beaton was prescribed Fluphenazine for the past ten years, which permitted him to maintain stable periods without schizophrenia symptoms.