Labor & Employment Law Daily Wrap Up, DISCRIMINATION—DISABILITY—N.D. Ala.: City defeats ADA suit over librarian’s termination following grant dispute, Facebook post, (Jul 16, 2026)

By Mandavi Singh, LL.M.

She could not demonstrate that her depression and anxiety substantially limited a major life activity or that city officials terminated her because they regarded her as disabled.

A municipal library employee failed to establish that she was disabled within the meaning of the ADA and therefore could not pursue her claim that the city unlawfully terminated her after she publicly disclosed her depression and anxiety on Facebook, a federal district court in Alabama has found. The court concluded that the librarian failed to present evidence showing her conditions substantially limited a major life activity or that city officials terminated her because they regarded her as disabled (Edwards v. City of Leeds, No. 2:24-cv-01386-ACA (N.D. Ala. July 14, 2026)).

Librarian. The employee served as Children's Director at the Leeds Jane Culbreth Library, a department of the City of Leeds, Alabama. She managed children's services, organized programming, and prepared grant applications. Although the Leeds Library Board established library policy and supervised the library director, personnel decisions regarding library employees ultimately rested with the city through the mayor.

The employee had experienced depression and anxiety since childhood and managed her conditions through prescription medication and counseling. She had informed the library's former director of her diagnosis and occasionally used paid leave as mental health days. However, she never sought a workplace accommodation because of her conditions, and her personnel records contained no documentation reflecting her depression or anxiety.

Grant application dispute. The dispute arose in April 2022 after the library director's position became vacant. The Library Board wanted the librarian to prepare a grant application to secure additional funding before the filing deadline. The employee, however, believed the application required the signature of a library director and therefore could not properly be submitted while the position remained vacant. Even after a board member instructed her to complete the application and obtain the board chairman's signature, she declined to do so because she believed no qualified individual could execute the application. As a result, the deadline passed without the application being submitted.

When a board member later questioned why the application had not been filed, the discussion became tense. The board member subsequently reported that the employee had been disrespectful and insubordinate. The following day, the librarian posted a photograph of herself at the library on Facebook, stating that she was near her "breaking point," suffered from "high stress, high anxiety, depression, and vulnerability," and that public and school librarians had been persecuted in recent years.

Termination. At its next meeting, the Library Board discussed the failed grant application, the confrontation, and the Facebook post. Although board members could not identify a specific policy violated by the social media post, they viewed it as unprofessional. They unanimously recommended that the city discipline the librarian, including termination. The mayor subsequently terminated her employment, citing insubordination, inappropriate demeanor, violation of the city's social media policy, and concerns regarding the safety of patrons and employees. The librarian then filed suit under the ADA.

ADA claim. Granting summary judgment for the city, the court held that the librarian failed to establish the threshold requirement that she was disabled under the ADA.

Although the court accepted that the employee suffered from depression and anxiety, it found she presented no evidence that those conditions substantially limited one or more major life activities. Citing Bragdon v. Abbott, 524 U.S. 624 (1998), the court emphasized that "The [ADA] is not operative, and the definition not satisfied, unless the impairment affects a major life activity." Relying on Lewis v. City of Union City, 934 F.3d 1169 (11th Cir. 2019), the court concluded that evidence of a diagnosis, prescription medication, and counseling alone was insufficient without proof that the impairment substantially limited a major life activity.

Further, the court was unpersuaded by the employee's alternative argument that the city regarded her as disabled after reading the Facebook post. Even assuming board members perceived her as having a mental impairment, the court found no evidence that they recommended discipline because of that perception. Instead, the undisputed record showed that discussions about disciplinary action began before the Facebook post, following the employee's refusal to submit the grant application and her contentious interaction with a board member. Nor did the employee identify discriminatory remarks, similarly situated non-disabled employees who received more favorable treatment, or other evidence connecting the termination to disability discrimination. Again relying on Lewis, the court concluded that she failed to establish the causation required under the ADA's "regarded as" provision.

Likewise, the court rejected the employee's contention that the city's stated reasons for her dismissal were pretextual. It observed that “An employer may fire an employee for a good reason, a bad reason, a reason based on erroneous facts, or no reason at all if the action is not for a discriminatory reason.” The court further noted that the pretext inquiry “centers on the employer's beliefs, not the employee's beliefs.” Thus, it concluded that the librarian presented no evidence suggesting that city officials did not honestly believe the reasons they gave for terminating her employment. Because she failed to establish either an actual disability or that the city acted because of a perceived disability, the court entered summary judgment in favor of the city.

The case is No. 2:24-cv-01386-ACA.

Judge: Axon, A.

Attorneys: Richard A. Bearden (Massey Stotser & Nichols) for Virginia Edwards. Hugh Cannon Lawley (Clark, May, Price, Lawley, Duncan & Paul) for City of Leeds, Alabama.

Companies: City of Leeds, Alabama

Cases: DisabilityDiscrimination Discrimination Discharge AlabamaNews