Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346 (4th Cir. 1996). · Go Syfert
Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346 (4th Cir. 1996). Cases Citing This Book View Copy Cite
ScopeAbrogated by Baird ex rel. Baird v. Rose on other grounds: 6 citing opinions limit it to other grounds.
6 on other grounds
How later opinions annotate it (1 example)
Counts are distinct citing opinions whose annotation names this case. The flag stays red when any point is no longer good law; the scope says how far that reaches.
Quick Summary

A twenty-five-pound lifting limitation does not constitute a significant restriction on major life activities sufficient to establish a disability under the Americans with Disabilities Act.

An employee with a back injury and a twenty-five-pound lifting restriction sued her employer for disability discrimination and wrongful discharge after the company refused to reassign her to a vacant position and terminated her. The central question is whether this specific lifting limitation constitutes a disability under the Americans with Disabilities Act. The court holds that a twenty-five-pound lifting restriction does not significantly restrict an individual's ability to perform major life activities, such as lifting or working, compared to the average person. Because the plaintiff failed to establish that she had a qualifying disability, she could not prevail on her federal or state discrimination claims. The court affirms the summary judgment granted to the employer.

234 citation events (103 in the last 25 years) across 58 distinct courts.
Treatment trajectory · 1997 → 2026 · click a year to view as-of
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Cited for
At page 349 Determining if lifting limitation constitutes significant restriction69 citing casesLike the Eighth Circuit, we hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities— does not constitute a significant restriction on one’s ability to lift, work, or perform any other major life activity.18 citing courts put it this way · Yellow (The case is red on another point: 6 of 6 annotating opinions limit the red to other grounds, and no citing court has tied that point to this proposition (6 citing treatments of its own).) · Yellow (The case is red on another point: 6 of 6 annotating opinions limit the red to other grounds, and no citing court has tied that point to this proposition (3 citing treatments of its own).) · 1 cautionary
  • Melvin Burns v. Coca-Cola Enter., Inc., 222 F.3d 247 (6th Cir. 2000).published Cited "but see" · 3 cites
    But see Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346 , (4th Cir.1996) (holding, “as a matter of law, that a twenty-five pound lifting limitation particularly when compared to an average person’s abilities — does not con…
  • Duncan v. Washington Metro. Area Transit Auth., 240 F.3d 1110 (D.C. Cir. 2001).published 2 cites
    (hold[ing], as a matter of law, that a twenty-five pound lifting limitation--particularly when compared to an average person's abilities--does not constitute a significant restriction on one's ability to lift, work, or…)
  • Mullins v. Crowell, 74 F. Supp. 2d 1067 (N.D. Ala. 1999).published
    (We hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person's abilities — does not constitute a significant restriction on one’s ability to lift, work, or…)
  • Whitfield v. Pathmark Stores, Inc., 971 F. Supp. 851 (D. Del. 1997).published
    ([W]e hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities — does not constitute a significant restriction on one’s ability to life, work, o…)
  • Peggy Young v. United Parcel Serv., Inc., No. 11-2078 (4th Cir. Apr. 10, 2015).published 2 cites
    ([W]e hold, as a matter of law, that a twenty-five pound lift- ing limitation—particularly when compared to an average person’s abilities—does not constitute a significant restriction on one’s ability to lift, work, or…)
  • Young v. United Parcel Serv., Inc., 784 F.3d 192 (4th Cir. 2013).published
    ([W]e hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities— does not constitute a significant restriction on one’s ability to lift, work, or…)
  • Young v. United Parcel Serv., Inc., 707 F.3d 437 (4th Cir. 2013).published
    ([W]e hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities— does not constitute a significant restriction on one’s ability to lift, work, or…)
  • Sch. Comm. v. Massachusetts Comm'n Against Discrimination, 830 N.E.2d 1090 (Mass. App. Ct. 2005).published
    (as a matter of law, ... a twenty-five pound lifting limitation — particularly when compared- to an average person’s abilities — does not constitute a significant restriction on one’s ability to lift, work, or perform a…)
  • Mondzelewski v. Pathmark Stores, Inc., 976 F. Supp. 277 (D. Del. 1997).published
    ([W]e hold, as a matter of law, that a twenty-five pound lifting limitation— *280 particularly when compared to an average person’s abilities — does not constitute a significant restriction on one’s ability to lift, wor…)
  • Irvin v. Versatrim, LLC, 737 F. Supp. 3d 297 (E.D.N.C. 2024).published
    Ctr., 16 F. App’x 185, 185-86 (4th Cir. 2001) (per curiam) (unpublished); Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346, 349 (4th Cir. 1996) (per curiam), abrogated on other grounds by Baird ex rel.
Show 59 more citing cases
  • McDonald v. City of New York, 786 F. Supp. 2d 588 (E.D.N.Y. 2011).published
    (same, for twenty-five pound lifting limitation)
  • Smith v. Wynfield Dev. Co., 451 F. Supp. 2d 1327 (N.D. Ga. 2006).published
    Compare Reed v. Heil Co., 206 F.3d 1055 , 1061-62 (11th Cir.2000)(declining to determine whether lifting restriction fails as a matter of law to establish a disability within meaning of ADA); with Marinelli v. City of Erie, Penn., 216 F.3d…
  • Jones v. United Parcel Serv., Inc., 411 F. Supp. 2d 1236 (D. Kan. 2006).published
    (as a matter of law, 25-pound lifting restriction not a significant restriction on ability to lift, work, or *1258 perform other major life activity)
  • Buettner v. North Oklahoma Cnty. Mental Health Ctr., 158 F. App'x 81 (10th Cir. 2005).unpublished
    Inc., 302 F.3d 1152, 1160 (10th Cir.2002) (noting precedents from other circuits that ten and twenty-pound lifting restrictions are not substantially limiting, citing Pryor v. Trane Co., 138 F.3d 1024 , 1025 n. 2 (5th Cir.1998); McKay v. T…
  • Sharon Kay v. Lester Coggins Trucking, Inc., 141 F. App'x 824 (11th Cir. 2005).unpublished
    See Reed v. Heil Co., 206 F.3d 1055 , 1061 (11th Cir.2000) citing Thompson v. Holy Family Hosp., 121 F.3d 537, 539-40 (9th Cir.1997); Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346, 349 (4th Cir.1996); Aucutt v. Six Flags…
  • Bryant v. Caritas Norwood Hosp., 345 F. Supp. 2d 155 (D. Mass. 2004).published
    Ctr., 128 F.3d 1201, 1207 (8th Cir.1997) (“a general lifting restriction imposed by a physician, without more, is insufficient to constitute a disability within the meaning of the ADA”); Thompson v. Holy Family Hosp., 121 F.3d 537, 539-40…
  • Burton v. Potter, 339 F. Supp. 2d 706 (M.D.N.C. 2004).published
    Williams, 101 F.3d at 349.
  • Harris v. Franziska Racker Centers, Inc., 340 F. Supp. 2d 225 (N.D.N.Y. 2004).published
    “does not constitute a significant restriction on one’s ability to lift, work or perform any other major life activity”
  • Hockaday v. Brownlee, 370 F. Supp. 2d 416 (E.D. Va. 2004).published
    (holding, "as a matter of law, that a twenty-five pound lifting limitation does not constitute a significant restriction on one's ability to lift, work, or perform any other major life activity)
  • Lilly v. Mastec North Am., Inc., 302 F. Supp. 2d 471 (M.D.N.C. 2004).published
    Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346, 349 (4th Cir.1996), cert. denied, 520 U.S. 1240 , 117 S.Ct. 1844 , 137 L.Ed.2d 1048 (1997).
  • Howard Baer, Inc. v. Schave, 127 S.W.3d 589 (Ky. 2003).published 2 cites
    See Colwell v. Suffolk County Police Dept., 158 F.3d 635, 644 (2nd Cir.1998), cert. denied, 526 U.S. 1018 , 119 S.Ct. 1253 , 143 L.Ed.2d 350 (1999)(10-20 pound lifting restriction); Gutridge v. Clure, 153 F.3d 898 , 901 (8th Cir.1998), cer…
  • Velarde v. Associated Reg'l & Univ. Pathologists, 61 F. App'x 627 (10th Cir. 2003).unpublished
    See Lusk, 238 F.3d at 1241 , citing Thompson v. Holy Family Hospital, 121 F.3d 537, 540 (9th Cir.1997) (twenty-five pound lifting restriction is not a substantial limitation on the ability to lift); Williams v. Channel Master Satellite Sys…
  • Maxcene Mays v. Anthony J. Principi, 301 F.3d 866 (7th Cir. 2002).published 2 cites
    Cf. Stein v. Ashcroft, supra, 284 F.3d at 725-26 ; Duncan v. Washington Metropolitan Area Transit Authority, 240 F.3d 1110, 1115 (D.C.Cir.2001) (en banc); Snow v. Ridgeview Medical Center, 128 F.3d 1201, 1207 (8th Cir.1997); Williams v. Ch…
  • Thompson v. KN Energy, Inc., 177 F. Supp. 2d 1238 (D. Kan. 2001).published
    See, e.g., Huckans v. United States Postal Serv., 201 F.3d 448 (10th Cir.1999) (table) (finding thirty-five pound lifting restriction not substantially limiting); Thompson v. Holy Family Hosp., 121 F.3d 537, 539-40 (9th Cir.1997) (finding…
  • Thompson v. Archer Daniels Midland Co., 174 F. Supp. 2d 833 (C.D. Ill. 2001).published
    Thompson, 5 F.Supp.2d at 626 , citing Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346, 349 (4th Cir.1996); Aucutt v. Six Flags Over Mid-America, 85 F.3d 1311, 1319 (8th Cir.1996).
  • Shannon v. Henderson, No. 01-10346, 2001 WL 1223633 (5th Cir. Sept. 26, 2001).unpublished
    (rejecting the claim of an individual who could not lift more than twenty-five pounds)
  • Cox v. Civista Med. Ctr., 16 F. App'x 185 (4th Cir. 2001).unpublished
    However, in Williams, we noted that a lifting restriction of twenty-five pounds did not constitute a substantial limitation to a major life activity, including work. 101 F.3d at 349.
  • Rhoads v. Fed. Deposit Ins., 257 F.3d 373 (4th Cir. 2001).published 4 cites
    Id. at 348, 349.
  • Lusk v. Ryder Integrated Logistics, 238 F.3d 1237 (10th Cir. 2001).published
    (same as to twenty-five pound lifting restriction)
  • Washington v. George G. Sharp, Inc., 124 F. Supp. 2d 948 (E.D. Va. 2000).published
    “as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities — does not constitute a significant restriction on one’s ability to lift, work, or perform an…”
  • Buskirk v. Apollo Metals, 116 F. Supp. 2d 591 (E.D. Pa. 2000).published
    (holding that 25 pound lifting restriction not substantially limiting)
  • Fitch v. Solipsys Corp., 94 F. Supp. 2d 670 (D. Md. 2000).published
    The ADA and the EEOC interpretive guidelines define “major life activities” to include “working” and “lifting.” Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346, 349 (4th Cir.1996), cert. denied sub nom Williams v. Avnet, I…
  • Reed v. Heil Co., 206 F.3d 1055 (11th Cir. 2000).published 2 cites
    (twenty-five pound lifting restriction not a disability)
  • Lown v. JJ Eaton Place, 598 N.W.2d 633 (Mich. Ct. App. 1999).published
    See Thompson v Holy Family Hosp, 121 F3d 537, 539-540 (CA 9, 1997); Williams v Channel Master Satellite Systems, Inc, 101 F3d 346, 349 (CA 4, 1996); Aucutt v Six Flags Over Mid-America, Inc, 85 F3d 1311, 1319 (CA 8, 1996); Ray, supra. 7 In…
  • Rebarchek v. Farmers Coop. Elevator & Mercantile Ass'n, 60 F. Supp. 2d 1145 (D. Kan. 1999).published
    (Like the Eighth Circuit, we hold, as a matter of law, that a twenty-five pound lifting limitation — particularly when compared to an average person’s abilities— does not constitute a significant restriction on one’s ab…)
  • Reese v. Owens-Corning Fiberglas Corp., 31 F. Supp. 2d 908 (D. Kan. 1998).published
    Anthony Hosp., No. 96-6063, 1997 WL 57156, at *2 (10th Cir. Feb.12, 1997) (25-pound repetitive lifting restriction, without more, insufficient to demonstrate substantial limitation on major life activity of lifting where plaintiff failed t…
  • Gittens v. Garlocks Sealing Tech., 19 F. Supp. 2d 104 (W.D.N.Y. 1998).published
    “does not constitute a significant restriction on one’s ability to lift, work, or perform any other major life activity”
  • Miller v. Cohen, 52 F. Supp. 2d 389 (M.D. Pa. 1998).published
    See Thompson v. Holy Family Hosp., 121 F.3d 537, 539-40 (9th Cir.1997); Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346, 349 (4th Cir.1996); Aucutt v. Six Flags Over Mid-America, Inc., 85 F.3d 1311, 1319 (8th Cir.1996). 8 Whi…
  • Corrigan v. Perry, 961 F. Supp. 132 (E.D. Va. 1997).published
  • Gregory P. Burgard v. Super Valu Holdings, Inc., 113 F.3d 1245 (10th Cir. 1997).published
  • Duncan, Jimmy L. v. WMATA, 240 F.3d 1110 (D.C. Cir. 2000).published
  • Duncan, Jimmy L. v. WMATA, 240 F.3d 1110 (D.C. Cir. 2000).published
  • Pamela McKay v. Toyota Motor Mfg., U.S.A., Inc., 110 F.3d 369 (6th Cir. 1997).published
  • Cynthia Thompson v. Holy Fam. Hosp., 121 F.3d 537 (9th Cir. 1997).published
  • Jay Lawrence Halperin v. Abacus Tech. Corp., 128 F.3d 191 (4th Cir. 1997).published
  • Alfred F. Marinelli v. City of Erie, 216 F.3d 355 (3d Cir. 2000).published
  • Corrigan v. Perry, No. 97-1511, 1998 WL 129929 (4th Cir. Mar. 24, 1998).unpublished
  • Wyland v. Boddie Noell, No. 98-1163 (4th Cir. Nov. 17, 1998).unpublished
  • Daye v. Sch. Bd. of City of Norfolk, 18 F. App'x 125 (4th Cir. 2001).unpublished
  • Horth v. Gen. Dynamics Land Sys., Inc., 960 F. Supp. 873 (M.D. Pa. 1997).published
  • Serrano v. Cnty. of Arlington, 986 F. Supp. 992 (E.D. Va. 1997).published
  • Hazeldine v. Beverage Media, Ltd., 954 F. Supp. 697 (S.D.N.Y. 1997).published
  • Settle v. SW Rodgers, Co., 998 F. Supp. 657 (E.D. Va. 1998).published
  • Bivins v. Bruno's, Inc., 953 F. Supp. 1558 (M.D. Ga. 1997).published
  • Rhoads v. Fed. Deposit Ins., 956 F. Supp. 1239 (D. Md. 1997).published
  • Panzullo v. Modell's Pa., Inc., 968 F. Supp. 1022 (E.D. Pa. 1997).published
  • Imler v. Hollidaysburg Am. Legion Ambulance Serv., 731 A.2d 169 (Pa. Super. Ct. 1999).published
  • Thompson v. Dot Foods, Inc., 5 F. Supp. 2d 622 (C.D. Ill. 1998).published
  • Howell v. Sam's Club 8160/wal-mart, 959 F. Supp. 260 (E.D. Pa. 1997).published
  • Stewart v. Weast, 228 F. Supp. 2d 660 (D. Md. 2002).published
  • Smith v. Quikrete Companies, Inc., 204 F. Supp. 2d 1003 (W.D. Ky. 2002).published
  • Paris v. Arc/Davidson Cnty., Inc., 307 F. Supp. 2d 743 (M.D.N.C. 2004).published
  • BIAGAS v. Dist. of Columbia, 680 F. Supp. 2d 148 (D.D.C. 2010).published
  • Vass v. Riester & Thesmacher Co., 79 F. Supp. 2d 853 (N.D. Ohio 2000).published
  • Hoskins v. Oakland Cnty. Sheriff's Dep't, 44 F. Supp. 2d 882 (E.D. Mich. 1999).published
  • Barber v. Pepsi-Cola Pers., Inc., 78 F. Supp. 2d 683 (W.D. Mich. 1999).published
  • Piascyk v. City of New Haven, 64 F. Supp. 2d 19 (D. Conn. 1999).published
  • Biagas v. D.C., No. 2001-2578 (D.D.C. Jan. 25, 2010).published
  • Kirkendall v. United Parcel Serv., Inc., 964 F. Supp. 106 (W.D.N.Y. 1997).published
At page 348 Determining disability under the major life activity of working10 citing cases“physical or mental impairment that substantially limits one or more of the major life activities of such individual.”the opinion's own words at *348, quoted by 7 later opinions · 9 listed here
  • Cassity v. Geren, 749 F. Supp. 2d 380 (D.S.C. 2010).published
    See, Haulbrook v. Michelin N. America, 252 F.3d 696, 702 (4th Cir.2001); Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346, 348 (4th Cir.1996) (per curium).
  • Thomas v. Potter, 325 F. Supp. 2d 596 (M.D.N.C. 2004).published
    In Williams, the plaintiff had “restrictions that she refrain from lifting more than 25 pounds and pushing or pulling heavy objects.” Id. at 348.
  • Scott v. Montgomery Cnty. Gov't, 164 F. Supp. 2d 502 (D. Md. 2001).published
    Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346, 348 (4th Cir.1996).
  • Rhoads v. Fed. Deposit Ins., 257 F.3d 373 (4th Cir. 2001).published 4 cites
    Id. at 348, 349.
  • Betts v. Rector & Visitors of the Univ. of Virginia, 113 F. Supp. 2d 970 (W.D. Va. 2000).published
    Corp., 50 F.3d 1261, 1264-65 (4th Cir.1995); see also Martinson v. Kinney Shoe Corp., 104 F.3d 683, 686 (4th Cir.997); Williams v. Channel Master Satellite Sys., Inc., 101 F.3d 346, 348 (4th Cir.1996), ce rt. denied, 520 U.S. 1240 , 117 S.…
  • Petty v. Freightliner Corp., 113 F. Supp. 2d 808 (W.D.N.C. 2000).published
    Williams v. Channel Master Satellite Systems, Inc., 101 F.3d 346, 348-49 (4th Cir.1996), ce rt. denied, 520 U.S. 1240 , 117 S.Ct. 1844 , 137 L.Ed.2d 1048 (1997).
  • Corrigan v. Perry, 961 F. Supp. 132 (E.D. Va. 1997).published
  • Taliaferro v. Assocs. Corp. of North Am., 112 F. Supp. 2d 483 (D.S.C. 1999).published
  • Lamb v. Qualex, Inc., 28 F. Supp. 2d 374 (E.D. Va. 1998).published
At page 350 Assessing the objective standard for reasonable accommodation5 citing cases“the mcdonnell douglas test is designed to circumvent a factual dispute over the reasons for discharge, and is therefore most appropriate when the defendant disavows any reliance on discriminatory reasons for its adverse employment action.”1 citing court quotes it
  • Bob Nadler v. Francis J. Harvey, No. 06-12692, 2007 WL 2404705 (11th Cir. Aug. 24, 2007).unpublished
    “the mcdonnell douglas test is designed to circumvent a factual dispute over the reasons for discharge, and is therefore most appropriate when the defendant disavows any reliance on discriminatory reasons for its adverse…”
  • Donovan v. Potter, 589 F. Supp. 2d 598 (E.D.N.C. 2008).published
    “[b]y definition, the determination of reasonableness is an objective analysis, not a subjective one dominated by either party’s concerns”
  • Petty v. Freightliner Corp., 122 F. Supp. 2d 666 (W.D.N.C. 2000).published
    “The reasonableness of an accommodation is assessed objectively, and is not viewed subjectively from the concerns of either party.” Andrews v. Commonwealth, 2000 WL 1532333 , *1 (4th Cir.2000) (citing Williams v. Channel Master Satellite S…
  • Corrigan v. Perry, 961 F. Supp. 132 (E.D. Va. 1997).published
  • Andrews v. Commonwealth of VA, No. 99-1783 (4th Cir. Sept. 29, 2000).unpublished
Retrieving the full opinion text from the archive…
Linda WILLIAMS, Plaintiff-Appellant,
v.
CHANNEL MASTER SATELLITE SYSTEMS, INCORPORATED; Channel Master Communications, Incorporated; Avnet, Incorporated, Defendants-Appellees. Equal Employment Opportunity Commission; Equal Employment Advisory Council, Amici Curiae
96-1072.
Court of Appeals for the Fourth Circuit.
Nov 27, 1996.
Published opinion
101 F.3d 346
1996 WL 682213
1996 U.S. App. LEXIS 30888
ARGUED: Burton Craige, Patterson, Harkavy & Lawrence, L.L.P., Raleigh, NC, for Appellant. Robert John Gregory, Equal Employment Opportunity Commission, Washington, DC, for Amicus Curiae EEOC. Martin Nesbitt Erwin, Smith, Helms, Mulliss & Moore, L.L.P., Greensboro, NC, for Appel-lees. ON BRIEF: John J. Korzen, Smith, Helms, Mulliss & Moore, L.L.P., Greensboro, NC, for Appellees. C. Gregory Stewart, General Counsel, Gwendolyn Young Reams, Associate General Counsel, Vincent Black-wood, Assistant General Counsel, Equal Employment Opportunity Commission, Washington, DC, for Amicus Curiae EEOC. Douglas S. McDowell, Ann Elizabeth Reésman, Ellen Duffy McKay, McGuinness & Williams, Washington, DC, for Amicus Curiae Advisory Council.
Hall, Williams, Motz.
Cited by 80 opinions  |  Published
3 passages pin-cited by 4 cases
Pinpoint authority: bottom 39%
Citer courts: Fourth Circuit (2) · Eleventh Circuit (1) · Massachusetts Appeals Court (1)

Lead Opinion

OPINION

PER CURIAM:

Linda Williams appeals the district court’s grant of summary judgment to her employer on her claims for employment discrimination under the Americans With Disabilities Act (ADA), 42 U.S.C. §§ 12101 — 12213 . (1995), and the North Carolina Handicapped Persons Protection Act (NCHPPA), N.C.G.S. § 168A (Michie 1987), and for wrongful discharge under state common law. See Williams v. Avnet, 910 F.Supp. 1124 (E.D.N.C.1995). We affirm, albeit on narrower grounds than those on which the district court relied.

I.

The facts in this case are largely undisputed. In 1985, Linda Williams began working for Avnet, Inc.’s subsidiary, Channel Master Communications, in its Smithfield, North[*348] Carolina plant. In March 1992, Williams injured her neck and back in an automobile accident unrelated to work. Following the accident, Williams was unable to. work for several months. During this period she visited her doctor every three to four weeks, each time receiving a note excusing her from work until the next appointment. After each visit, Williams submitted the doctor’s note to the plant nurse, who extended her disability leave accordingly.

In September 1992, Williams’ orthopedist told her that she could return' to work, with the restrictions that she refrain from lifting more than 25 pounds and pushing or pulling heavy objects. The doctor rated her impairment as a 5% permanent partial disability of the back. Despite her doctor’s rating, it appears that neither Williams nor her employer knew at that time that her disability would be permanent.

When Williams received medical permission to work, she asked her employer, Channel Master, if she could return to the plant in any job position that fit her medical restrictions, even in a job at less pay. A personnel coordinator informed her that she would not be permitted to return to work until her doctor released her from “any and all restrictions” and she could perform all the duties she had before the accident. Later, discovery revealed that there were several job vacancies at the plant during this period of time that would have satisfied Williams’ medical restrictions. After her employer refused to reassign her to fighter duty work, Williams suggested other accommodations that Channel Master could make that would enable her to continue to perform the job she had held at the time of the accident. Channel Master refused to accommodate Williams’ condition in any way, and on October 2,1992, after she had received six months of disability leave, the company terminated her.

Williams then filed a timely charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC). The EEOC investigated her claim and determined that Channel Master had violated the ADA by refusing to accommodate Williams’ disability, by discharging her due to that disability, and by its policy of terminating temporarily disabled employees who can not return to work after six months.

The district court granted summary judgment to Channel Master finding that as a matter of law, Williams was not entitled to relief under the ADA, NCHPPA or on her common law claim of wrongful termination. The appeal followed.

II.

To establish a cause of action under the ADA, a plaintiff must demonstrate: “(1) that [s]he has a disability; (2) that [s]he is otherwise qualified for the employment or benefit in question; and (3) that [s]he was excluded from the employment or benefit due to discrimination solely on the basis of the disability.” Doe v. University of Maryland Medical Sys. Corp., 50 F.3d 1261, 1265 (4th Cir.1995); Tyndall v. National Educ. Ctrs., 31 F.3d 209, 212 (4th Cir.1994); White v. York Int’l Corp., 45 F.3d 357, 360-61 (10th Cir.1995).[1]

The ADA defines “disability” as “a physical or mental impairment that substantially limits one or more of the major fife activities of such individual; a record of such an impairment; or being regarded as having such an impairment.” 42 U.S.C. § 12102(2). The ADA regulations and EEOC interpretive guidelines list a number of major fife aetivi[*349]ties. See 29 C.F.R. § 1630.2© (1996) (caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working); 29 C.F.R. Pt. 1630, App. § 1630.2© (1996) (above activities plus sitting, standing, lifting and reaching).[2] Williams asserted that both lifting and working constituted major life activities that her impairment substantially limited.

The district court erred in two respects in analyzing whether Williams had established that she was disabled for purposes of the ADA. First, the court erred in failing even to address Williams’ asserted lifting limitation. Secondly, and perhaps more fundamentally, it erred in suggesting that working is not a major life activity, and that the general foreclosure test must be used to determine if any other major life activity is “substantially limited.” See Williams, 910 F.Supp. at 1131-33, 1136-37. The district court improperly described the regulatory language discussing working as a major life activity as “superfluous” and thus declared that “[wjhile some courts might entertain claims under the ‘major life activity’ of “working,’ this Court does not.” Id. at 1136. In fact, working is a major life activity, see Gupton v. Virginia, 14 F.3d 203, 205 (4th Cir.1994) (Rehabilitation Act); Dutcher v. Ingalls Shipbuilding, 53 F.3d 723, 724-27 (5th Cir.1995), and the general foreclosure test applies only to claims brought under the major life activity of working. See Gupton, 14 F.3d at 205 (applying general foreclosure test only to the major life activity of working); 29 C.F.R. § 1630.2(j)(3) (“With respect to the major life activity of working, the term substantially limits means significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes_”) (emphasis in original).

However, Williams nonetheless failed to establish that she had a disability sufficient to trigger the ADA. To determine if an employee is disabled under the ADA, a court must evaluate not just whether an employee is restricted but whether she is “[sjignificantly restricted” in performing a major life activity “as compared to the' condition, manner, or duration under which the average person, in the general population can perform that same major life activity.” 29 C.F.R. § 1630.2(j)(l)(ii). A court may also consider the “nature and severity of the impairment,” its “duration or expected duration” and any “permanent or long term impact.” 29 C.F.R. § 1630.2(j)(2). Moreover, when the major life activity at issue is working, the “inability to perform a single, particular job does not constitute a substantial limitation;” in this circumstance “substantially limits means significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes_” 29 C.F.R. § 1630.2(j)(3) (emphasis omitted).

Like the Eighth Circuit, we hold, as a matter of law, that a twenty-five pound lifting limitation—particularly when compared to an average person’s abilities—does not constitute a significant restriction on one’s ability to lift, work, or perform any other major life activity. See Aucutt v. Six Flags Over Mid-America, 85 F.3d 1311, 1319 (8th Cir.1996) (twenty-five pound lifting restriction did not “significantly restrict” major life activities).[3]

Even if an individual demonstrates she is disabled, the ADA requires her to establish that, “with or without reasonable accommodation, [she] can perform the essential functions of the employment position that [she] holds or desires.” 42 U.S..C. § 12111(8). The employer must arrange “reasonable accommodation” unless doing so imposes an “undue hardship.” 42 U.S.C. § 12112(b)(5). In determining whether the failure to accommodate Williams was reasonable, the district court deferred almost entirely to Channel Master’s judgment. The court held, as a[*350] matter of law, that if a proposed accommodation was not “obviously reasonable,” or its reasonableness “is a matter of some serious dispute, courts should defer to the employer’s business expertise.” Williams, 910 F.Supp. at 1133. The employer’s point of view should define “reasonableness,” the district court explained, because otherwise the determination of what is reasonable would “authorize[ ] the reviewing court to engage in a subjective, legislative exercise.” Id.

This approach was misguided. Courts are often asked to define reasonableness in various contexts; the standard of “reasonableness” is empty if “reasonable” means only “the employer’s opinion.” The district court’s approach is particularly inappropriate in the summary judgment context, where a court must view evidence in the light most favorable to the non-moving party. See Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587, 106 S.Ct. 1348, 1356, 89 L.Ed.2d 538 (1986) (citing United States v. Diebold, Inc., 369 U.S. 654, 82 S.Ct. 993, 8 L.Ed.2d 176 (1962)). By definition, the determination of reasonableness is an objective analysis, not a subjective one dominated by either party’s concerns. In assessing objective reasonableness, the governing statute provides guidance. See 42 U.S.C. § 12111(9). It provides that “ ‘reasonable accommodation’ may include” a number of listed measures; obviously Congress considered these types of accommodations to be reasonable. Examples in § 12111(9)(B) include “job restructuring, ... reassignment to a vacant position, [and] acquisition or modification of equipment or devices.” Thus, the district court also erred in suggesting that a qualified ADA plaintiff can never rely on reassignment to a vacant position as a reasonable accommodation.[4]

Although the district court erred in its mode of analyzing whether Channel Master’s failure to accommodate Williams was reasonable, it nonetheless properly granted Channel Master summary judgment on the ADA claim because Williams failed to establish that she was disabled under the ADA.

III.

The district court also properly rejected Williams’ two state law claims.

We note that the standards under the NCHPPA are narrower than under the ADA. See N.C. Gen.Stat. § 168A (Michie 1987); Burgess v. Your House of Raleigh, Inc., 326 N.C. 205, 388 S.E.2d 134, 138 (1990) (“[T]he North Carolina Act has a more restrictive definition of a ‘handicapped person’ in that it defines ‘major life activities’ more narrowly than the federal act defines the term.”). Since Williams is not disabled for the purposes of the ADA, she similarly is not disabled for the purposes of the NCHPPA.

Finally, the district court concluded that Williams could not prevail on her common law claim of wrongful discharge in violation of public policy. The court found that without a legally cognizable disability, Williams could not claim that she was a victim of disability discrimination. We agree. :

AFFIRMED.

WILLIAMS, C.J., concurs.
1

The district court improperly relied, Williams, 910 F.Supp. at 1131, on a proof scheme based on the approach that the Supreme Court took in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973). By readjusting burdens between the plaintiff and defendant, the McDonnell Douglas test is designed to circumvent a factual dispute over the reasons for discharge, and is therefore most appropriate when "the defendant disavows any reliance on discriminatory reasons for its adverse employment action.” Ennis v. National Ass'n of Bus. and Educ. Radio, Inc., 53 F.3d 55, 57-58 (4th Cir.1995); Barth v. Gelb, 2 F.3d 1180, 1185-87 (D.C.Cir.1993), cert. denied, - U.S. -, 114 S.Ct. 1538, 128 L.Ed.2d 190 (1994). Here, the parties do not dispute that the reason that Channel Master did not permit Williams to return to her job was that her back injury prevented her from performing her assigned tasks without accommodation. The McDonnell Douglas "inferential proof scheme” is not appropriate when, as here, the reason for discharge is undisputed.

2

The EEOC interpretive guidelines, "while not controlling upon the courts by reason of their authority, do constitute a body of experience and informed judgment .to which courts and litigants may properly resort for guidance.” Meritor Sav. Bank, FSB v. Vinson, 477 U.S. 57, 65, 106 S.Ct. 2399, 2404, 91 L.Ed.2d 49 (1986) (citations and internal quotation marks omitted).

3

Because we find that Williams does not qualify as a disabled individual under the ADA, we need not reach the district court's holding regarding the legality of the asserted Avnet policy.

4

The district court relied on Myers v. Hose, 50 F.3d 278, 284 (4th Cir.1995), as supporting its conclusion that reassignment to a vacant position can never be a reasonable accommodation in ADA cases. This conclusion is contrary to congressional direction and is in no way required by our Myers decision. Myers noted only that a particular accommodation does not become federally mandated merely because an employer "elects to establish it as a matter of policy.” Id.

Concurrence

WILLIAMS, Circuit Judge,

concurring:

I agree with the majority’s reasoning and holding that Linda Williams is not disabled within the meaning of the Americans with Disabilities Act (ADA) and that the district court properly rejected Williams’s state law claims. See Majority Op. at 348-350, 350. Having reached those conclusions, I would not reach the issue of reasonable accommodation as discussed in the majority’s opinion in dicta on pages 349-350. See Karsten v. Kaiser Foundation Health Plan, 36 F.3d 8, 11-12 (4th Cir.1994) (per curiam) (stating that alternative holdings should be avoided).