The Difficulty Of Defining A Disability—Anxiety

In today's world, countless individuals suffer from anxiety in its various forms. According to the World Health Organization, in 2019, 301 million people in the world had an anxiety disorder, which makes anxiety disorders “the most common of all mental disorders.”¹ But is “anxiety” a “disability” in a legal sense? Is someone with “anxiety” entitled to reasonable accommodations? The answer is—as is often the case with legal issues—it depends.

The Michigan Court of Appeals considered the issue in Tyler v. Kalamazoo Public Schools,  2024 WL 203791 (Mich. Ct. App. Jan. 18, 2024). There, the plaintiff was a school teacher who alleged that, due to the mask requirements occurring under COVID-19 protocols, she experienced symptoms of anxiety. A physician diagnosed the plaintiff with “adjustment disorder with anxiety and depression” and treated her for “anxiety, stress, frustration, and depression [she] experienced in the last few years, largely as [a] result