No COVID vaccine, no ADA disability claim, federal court rules

The Fifth Circuit found the causal chain too indirect. Pietsch was working with his heart condition before the vaccine mandate came into play. His impairment did not stop him from doing his job. It stopped him from getting a vaccine, which then stopped him from keeping that specific job. That extra step, the court said, was one step too many under the law. 

The court drew on an earlier ruling – though one carrying persuasive rather than binding authority – involving similar facts, where employees argued that health conditions preventing vaccination made them disabled under the ADA. That decision had already established that this kind of indirect, multi-step limitation does not meet the legal bar. 

In a separate concurring opinion, Circuit Judge Don Willett put it plainly: disability under the ADA turns on what an impairment limits directly, not on what it may set in motion down the line. Congress designed the law to be read broadly, he wrote, but not without limits. 

For HR professionals, two takeaways stand out. First, approving a medical exemption is not the same as acknowledging that an employee has a legally recognized disability. Pietsch himself admitted in his deposition that FMC never made that admission – and the court agreed it was not required to. 

Second, while the court’s ruling turned entirely on whether Pietsch had a qualifying disability – not on whether FMC’s accommodations were adequate – the case is a reminder that maintaining a clear record of the interactive accommodation process and any alternative positions offered remains sound practice for employers. That paper trail becomes important if and when a case does reach the point of scrutinizing what an employer actually did.