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Actors/Disability

The U.S. Court of Appeals for the Fourth Circuit held that an actress who suffered from post-traumatic stress disorder and severe depression wasn't disabled within the meaning of the Americans with Disabilities Act. Rohan v. Networks Presentations LLC, 03-1637. Affirming on its own grounds, the Fourth Circuit determined that actress Tess Rohan, who had been appearing in a tour production of the musical “Jekyll & Hyde,” had failed to establish that her struggles with social interaction were “sufficiently severe” to show a substantial limitation under 42 U.S.C. Sec. 12102(2)(A). The appeals court also concluded that Rohan failed to establish that the production company had regarded her as substantially limited, as required by 42 U.S.C. Sec. 12102(2)(C).


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