Termination for Misconduct Did Not Violate ADA

An employer that terminated an employee for erratic and disruptive behavior caused by her bipolar affective disorder did not violate the Americans with Disabilities Act (ADA) because the employee's conduct rendered her unqualified for her position and she never requested a reasonable accommodation, according to the 8th US Circuit Court of Appeals. Ameriprise Financial Inc employed Marissa Walz as a process analyst from 1996 to 2012. She had been diagnosed with bipolar affective disorder. Beginning in March 2012, her co-workers and supervisor began noticing behavioral problems, including inappropriate outbursts during meetings, talking very rapidly and not making sense, becoming excited and easily agitated, and sending incomprehensible e-mails.