Rhoads v. F.D.I.C.

A financial analyst suffered from asthma and related migraine headaches, which were made worse by exposure to secondhand smoke. Although the employee had been allowed to work from home for a period of time, she was ultimately fired for failing to report back to work at a bank facility after a new smoke-free policy had been implemented. The employee sued the bank for discriminating against her based on her health condition in violation of state and federal law. The court of appeals found that the employee’s claims for reasonable accommodation and unlawful termination failed because she was unable to prove that she was disabled under the Americans with Disabilities Act (ADA). Specifically, the court found that the employee did not prove that she was “substantially limited” in her ability to gain work in her field because of her smoke-induced asthma and migraines. However, the court ruled that the employee’s retaliation claim could proceed because she had presented sufficient evidence to raise a question about whether she was terminated based on her attempts to enforce her rights under the ADA.


Rhoads v. Fed. Deposit Ins. Corp., 257 F.3d 373 (4th Cir. 2001).

  • United States
  • Jul 12, 2001
  • U.S. Court of Appeals for the Fourth Circuit


Plaintiff Lori Rhoads

Defendant Federal Deposit Insurance Corporation, in its capacity as receiver for Standard Federal Savings Bank and Standard Federal Savings Association

Legislation Cited

Americans with Disabilities Act

Family and Medical Leave Act

Maryland Wage and Payment and Collection Law

Maryland Worker's Compensation Act

Montgomery County (MD) Human Rights Law

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