William D. Adams v. Citizens Advice Bureau, 187 F.3d 315 (2d Cir. 1999). · Go Syfert
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William D. Adams v. Citizens Advice Bureau, 187 F.3d 315 (2d Cir. 1999). Cases Citing This Book View Copy Cite
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cited 3× by 3 distinct cases, 2008–2012 · 2 courts · …temporary, non-chronic impairments of short duration, with little or no long-term or permanent impact, are usually not disabilities. at p. 316 ⚠ not in text
43 citation events (43 in the last 25 years) across 8 distinct courts.
Strongest positive: Gonzalez v. Wicked Taco LLC (nyed, 2025-01-31)
Treatment trajectory · 2001 → 2026 · click a year to view as-of
2001 2013 2026
Top citers, strongest first. 31 distinct citers. How cited ↗
discussed Cited as authority (rule) Gonzalez v. Wicked Taco LLC
E.D.N.Y · 2025 · confidence medium
It is well-settled, however, that a “‘temporary impairment’ lasting only a few months is, ‘by itself, too short a duration . . . to be substantially limiting.’” Francis v. Hartford Bd. of Educ., 760 F. App’x 34 , 36 (2d Cir. 2019) (quoting Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999)); see also Levine v. Smithtown Cent.
cited Cited as authority (rule) Baskerville v. CBS News Inc.
D.D.C. · 2022 · confidence medium
Credit Union, 789 F. Supp. 2d 27, 38 (D.D.C. 2011) (citing Adams v. Citizens Advice Bureau, 187 F.3d 315, 316 (2d Cir. 1999) (per curiam)); Ellis v. Georgetown Univ.
cited Cited as authority (rule) Durr v. Slator
N.D.N.Y. · 2021 · confidence medium
June 19, 2020) (quoting Adams v. Citizens Advice Bureau, 187 F.3d 315, 317 (2d Cir. 1999)).
discussed Cited as authority (rule) Lewis v. Kaleida Health
W.D.N.Y. · 2021 · confidence medium
“A ‘temporary impairment’ lasting only a few months,” however, “is, ‘by itself, too short in duration . . . to be substantially limiting.’” De La Rosa v. Potter, 427 F. App’x 28, 29 (2d Cir. 2011) (summary order) (quoting Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999)). “[A] plaintiff [must] do more than simply allude to her impairments in her pleadings; she must plead how those impairments significantly impacted major life activities, or she will not survive a motion to dismiss.” Collins v. Giving Back Fund, 2019 WL 3564578 , at *13 (S.D.N.Y.
discussed Cited as authority (rule) Montague v. National Grid USA
W.D.N.Y. · 2020 · confidence medium
“A ‘temporary impairment’ lasting only a few months,” however, “is by itself, too short in duration . . . to be substantially limiting,’” id. at *10, quoting De La Rosa, supra, 427 F. App’x at 29 (quoting in turn Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999)).
discussed Cited as authority (rule) Van Ever-Ford v. State of New York
W.D.N.Y. · 2020 · confidence medium
“A ‘temporary impairment’ lasting only a few months,” however, “is, ‘by itself, too short in duration . . . to be substantially limiting.’” De La Rosa v. Potter, 427 F. App’x 28, 29 (2d Cir. 2011) (summary order) (quoting Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999)).
discussed Cited as authority (rule) Robles v. Medisys Health Network, Inc. (2×) also: Cited "see"
E.D.N.Y · 2020 · confidence medium
In addition, the Second Circuit has explicitly left open the question of “whether temporary injuries are per se unprotected under the ADA.” Adams v. Citizens Advice Bureau, 187 F.3d 315, 317 (2d Cir. 1999) (per curiam).
cited Cited as authority (rule) Nadel v. Shinseki
S.D.N.Y. · 2014 · confidence medium
Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (per curiam) (holding injury impairing ability to work for three and a half months temporary and not covered by the ADA).
discussed Cited as authority (rule) Kruger v. Hamilton Manor Nursing Home
W.D.N.Y. · 2014 · confidence medium
Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (temporary neck, back, and knee injury lasting three and one-half months is not a disability within the meaning of the ADA); De La Rosa v. Potter, 427 Fed.Appx. 28, 29 (2d Cir.2011) (temporary back injury not substantially limiting).
discussed Cited as authority (rule) Palmieri v. City of Hartford
D. Conn. · 2013 · confidence medium
The court notes that the Second Circuit has determined that, “A ‘temporary impairment’ lasting only a few months is, ‘by itself, too short in duration ... to be substantially limiting.’ ” De La Rosa v. Potter, 427 Fed.Appx. 28, 29 (2d Cir.2011) (quoting Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999)).
discussed Cited as authority (rule) Wanamaker v. Westport Board of Education
D. Conn. · 2012 · confidence medium
Jan. 15, 2008) (“To establish a disability under the ADA, there must be some proof of permanency.”); Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999); Williams v. Salvation Army, 108 F.Supp.2d 303, 312-13 (S.D.N.Y.2000) (“temporary, non-chronic impairments of short duration, with little or no long-term or permanent impact, are usually not disabilities.”).
cited Cited as authority (rule) Quintell Etheridge v. Fedchoice Federal Credit Union
D.D.C. · 2011 · confidence medium
Adams v. Citizens Advice Bureau, 187 F.3d 315, 316 (2d Cir. 1999) (per curiam).
cited Cited as authority (rule) Etheridge v. Fedchoice Federal Credit Union
D.D.C. · 2011 · confidence medium
Adams v. Citizens Advice Bureau, 187 F.3d 315, 316 (2d Cir.1999) (per curiam).
discussed Cited as authority (rule) De La Rosa v. Potter
2d Cir. · 2011 · confidence medium
A “temporary impairment” lasting only a few months is, “by itself, too short in duration ... to be substantially limiting.” Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (internal alteration and quotation marks omitted).
discussed Cited as authority (rule) Guary v. Upstate National Bank
W.D.N.Y. · 2009 · confidence medium
See Jackson v. Nor Loch Manor HCF, 134 Fed.Appx. 477, 477 (2d Cir.2005) (surgical procedure requiring a temporary absence from work is “not enough to sustain a claim under the ADA”); Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-317 (2d Cir.1999) (where employee’s automobile accident injuries caused a three- and-a-half month absence, with no evidence of substantial ongoing limitations, employee was not disabled within the meaning of the ADA); Colwell v. Suffolk County Police Dep’t, 158 F.3d 635, 646 (2d Cir.1998) (“a seven-month impairment [with unspecific residual,, ongoing lim…
discussed Cited as authority (rule) Duncan v. Harvey
D.D.C. · 2007 · confidence medium
Dist., 437 F.3d 797, 802 (8th Cir.2006) (surgery requiring nine-month leave of absence insufficient to show long-term impairment); Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (injury lasting three and one-half months “too short in duration ... to be substantially limiting”); Thompson v. Rice, 422 F.Supp.2d 158, 167 (D.D.C.2006) (brain hemorrhage requiring two-day hospital stay and six weeks of sick leave of temporary duration).
cited Cited as authority (rule) Ruhlmann v. Ulster County Department of Social Services
N.D.N.Y. · 2002 · confidence medium
Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (temporary impairment of ability to work is not “substantially limiting”).
discussed Cited as authority (rule) Anyan v. New York Life Insurance
S.D.N.Y. · 2002 · confidence medium
The Second Circuit has repeatedly found that temporary injuries requiring claimants to take a few months off from work are “too short [in] duration to be ‘substantially limiting.’ ” Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (quoting Colwell v. Suffolk County Police Dep’t, 158 F.3d 635, 646 (2d Cir.1998), cert. denied, 526 U.S. 1018 , 119 S.Ct. 1253 , 143 L.Ed.2d 350 (1999)).
discussed Cited "see" Murray v. Wal-Mart Stores East, LP
D. Conn. · 2025 · signal: see · confidence high
See Adams v. Citizens Advice Bureau, 187 F.3d 315 , 316–17 (2d Cir. 1999) (noting that a temporary injury resulting from a car crash resulting in missing work for approximately three months, with “no evidence” of substantial “limit[s] in major life activities as a result of that injury,” did not qualify as a disability).
discussed Cited "see" Alvarez v. New York City Department of Education
S.D.N.Y. · 2021 · signal: see · confidence high
See id. (affirming summary judgment to defendant on ADA claim where plaintiff was unable to work for three-and-a-half months); Colwell v. Suffolk Cty.
discussed Cited "see" Veldran v. DeJoy
2d Cir. · 2021 · signal: see · confidence high
See Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999) (holding plaintiff was not disabled within meaning of ADA where his injury lasted only three and one-half months and he failed to present evidence of a substantial limitation on a major life activity). 2 While a temporary impairment can be covered if it is sufficiently severe, see 29 C.F.R.
discussed Cited "see" McCarrick v. Corning, Inc.
W.D.N.Y. · 2019 · signal: see · confidence high
See Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir. 1999) (per curiam) (plaintiff did not suffer from a disability under the ADA where his back, neck, and knee injuries rendered him unable to work for three- and-a-half months); Kruger v. Hamilton Manor Nursing Home, 10 F. Supp. 3d 385, 389 (W.D.N.Y. 2014) (“Plaintiff admits that the physical limitation she sustained from breaking her arm only ‘temporarily affected’ her daily activities.
cited Cited "see" Francis v. Hartford Board of Education
2d Cir. · 2019 · signal: see · confidence high
See De La Rosa v. Potter, 427 F. App’x 28, 29 (2d Cir. 2011) (quoting Adams, 187 F.3d at 316‐17). 3 permanent impact, are usually not disabilities.”).
cited Cited "see" Ragusa v. Malverne Union Free School District
E.D.N.Y · 2008 · signal: see · confidence high
See Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999).
cited Cited "see" Levine v. Smithtown Central School District
E.D.N.Y · 2008 · signal: see · confidence high
See Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999).
discussed Cited "see, e.g." Soto v. Marist College
S.D.N.Y. · 2019 · signal: see also · confidence medium
Hosp., 1 F. Supp. 2d 318, 321 (S.D.N.Y. 1998) (dismissing ADA claim where the plaintiff “stated that he suffered a back injury which forced him temporarily to leave work,” but “d[id] not claim that his injury was permanent”); see also Adams v. Citizens Advice Bureau, 187 F.3d 315, 316 (2d Cir. 1999) (affirming summary judgment for the defendant where the plaintiff “was unable to work only for three and one-half months”).
discussed Cited "see, e.g." Emmons v. City University of New York
E.D.N.Y · 2010 · signal: see, e.g. · confidence medium
Feb. 9, 2010) (internal quotation marks omitted); see Toyota, 534 U.S. at 198 , 122 S.Ct. 681 ; see, e.g., Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (finding employee not disabled under ADA where temporary physical injuries prevented him from working for three and a half months).
discussed Cited "see, e.g." Attis v. Solow Realty Development Co.
S.D.N.Y. · 2007 · signal: see, e.g. · confidence medium
See, e.g., Adams v. Citizens Advice Bureau, 187 F.3d 315, 316 (2d Cir.1999) (plaintiffs neck, back and knee injuries were not substantially limiting because plaintiff “proffered no evidence showing that, despite the temporary nature of his injury, he was substantially limited in major life activities as a result of that injury”); Colwell v. Suffolk County Police Dep’t, 158 F.3d 635, 646 (2d Cir.1998) (temporary impairment of seven months was, by itself, “too short [in] duration ... to be substantially limiting”); Thompson v. Fed.
discussed Cited "see, e.g." Rector v. Sylvania
S.D.N.Y. · 2003 · signal: see also · confidence medium
Id. at 321-322 ; see also Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-317 (2d Cir.1999)(stating that plaintiffs injuries which precluded him from working for three and one-half months was “too short in duration ... to be substantially limiting”); Colwell v. Suffolk County Police Dep’t, 158 F.3d 635, 646 (2d Cir.1998), cert. denied, 526 U.S. 1018 , 119 S.Ct. 1253 , 143 L.Ed.2d 350 (1999) (holding temporary impairment of seven months not substantially limiting); Williams v. The Salvation Army, 108 F.Supp.2d 303, 312-13 (S.D.N.Y.2000) (asserting “temporary, non-chronic impairments …
discussed Cited "see, e.g." Amendola v. Henderson
E.D.N.Y · 2001 · signal: see, e.g. · confidence medium
See, e.g., Adams v. Citizens Advice Bureau, 187 F.3d 315, 316-17 (2d Cir.1999) (three and one-half month inability to work while recovering from surgery not covered by ADA); Colwell, 158 F.3d at 646 (seven-month recuperation following hospitalization is of too short a duration to be substantially limiting); Sanders v. Arneson Prod., 91 F.3d 1351, 1354 (9th Cir.1996) (three and one-half month impairment with minimal residual effects not substantially limiting), cert. denied, 520 U.S. 1116 , 117 S.Ct. 1247 , 137 L.Ed.2d 329 (1997); Halperin v. Abacus Tech.
cited Cited "see, e.g." Felix v. New York City Transit Authority
S.D.N.Y. · 2001 · signal: see also · confidence medium
See also Adams v. Citizens Advice Bureau, 187 F.3d 315, 317 (2d Cir.1999) (“[W]e have no occasion to consider whether temporary injuries are per se unprotected under the ADA.”). 2.
Retrieving the full opinion text from the archive…
William D. ADAMS, Plaintiff-Appellant,
v.
CITIZENS ADVICE BUREAU, Defendant-Appellee
1998.
Court of Appeals for the Second Circuit.
Aug 20, 1999.
187 F.3d 315
1999 U.S. App. LEXIS 19739
William D. Adams, pro se, Bronx, N.Y., Plaintiff-Appellant, Ira G. Rosenstein, Orrick, Herrington & Sutcliffe, New York, N.Y., for Defendant-Appellee
Calabresi, Cabranes, Sotomayor.
Cited by 34 opinions  |  Published
Pinpoint authority: bottom 53%
PER CURIAM:

Plaintiff-appellant, William D. Adams, pro se, appeals from the judgment of the United States District Court for the Southern District of New York (Wood, Judge), granting summary judgment for the defendant, Citizens Advice Bureau (“CAB”). We affirm.

I.

From May 8, 1995 to September 8,1995, Adams was employed as a family monitor and security guard at CAB, a social services organization. He was injured on August 14, 1995, in an automobile accident, of which he notified his supervisor. On August 30, 1995, he provided CAB with a note from his chiropractor, indicating that he was unable to work “for an indefinite period.” CAB then requested a statement from a medical doctor. After Adams failed to produce the requested documentation, CAB terminated him on September 8, 1995. Adams concedes that from August 14, 1995 to November 30, 1995, he was not able to perform the security function of his job, due to his neck, back, and knee injury.

On January 22, 1998, Adams instituted this action, in forma pauperis and pro se, alleging that his termination constituted discrimination on the basis of disability. The district court granted defendant’s motion for summary judgment, on the ground that plaintiffs temporary injury did not constitute a “disability” within the meaning of the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. (1994) (“ADA”).

II.

We review de novo the decision of the district court to grant summary judgment. See Beatie v. City of New York, 123 F.3d 707, 710 (2d Cir.1997).

The only issue before this court is whether Adams suffered from a disability within the meaning of the ADA. To be covered by the ADA, Adams must demonstrate that he suffered from “a physical or mental impairment that substantially limit[ed] one or more of [his] major life activities.” 42 U.S.C. § 12102(2) [1]

There is no dispute that Adams’s injury was, for the purposes of this claim, temporary. Before the district court, Adams agreed that he was unable to work only for three and one-half months, from August 14, 1995 to November 30, 1995. [2] He proffered no evidence showing that, despite the temporary nature of his injury, he was substantially limited in major life activities as a result of that injury. Because this court has found a temporary impairment of seven months, by itself, “too short [in][*317] duration ... to be ‘substantially limiting,’ ” Colwell v. Suffolk County Police Dep’t, 158 F.3d 635, 646 (2d Cir.1998), cert. denied, - U.S. -, 119 S.Ct. 1253, 143 L.Ed.2d 350 (1999), Adams has failed to make out a claim that he was disabled within the meaning of the ADA.

The Magistrate Judge’s report and recommendation, adopted by the district court, engages in a case-specific analysis to determine whether this plaintiff was substantially limited in a major life activity by his temporary injury. As a result, we have no occasion to consider whether temporary injuries are per se unprotected under the ADA. Compare Graaf v. North Shore Univ. Hosp., 1 F.Supp.2d 318, 321 (S.D.N.Y.1998) and Davis v. Bowes, No. 95 Civ. 4765, 1997 WL 655935, at *15 (S.D.N.Y. Oct.20, 1997), with Aldrich v. Boeing Co., 146 F.3d 1265, 1270 (10th Cir.1998), ce rt. denied, - U.S. -, 119 S.Ct. 2018, 143 L.Ed.2d 1030 (1999) (“[A]n impairment need not be permanent in order to rise to the level of a disability.”). The question is open in this circuit and we intimate no opinion on it.

Having carefully reviewed the record and examined appellant’s argument, we order that the district court’s order of judgment be AFFIRMED.

1

. The ADA also defines disability as "a record of ... an impairment” that substantially limits one or more major life activities or "being i -garded as having such an impairment.” Id. Adams has made no effort to establish his disability under either of these alternative definitions.

2

. Adams made no claim in the court below that he suffered from residual limitations on his capacity to perform work as a result of this temporary disability. Cf. 29 C.F.R. § 1630.2(j)(2) (1998) (providing that one of the three factors to evaluate in determining whether an individual is substantially limited is "[t]he permanent or long term impact, or the expected permanent or long term impact of or resulting from the impairment”).