A plaintiff who claims she suffers anxiety and distress while riding in an elevator, driving, and entering dangerous areas in St. Louis does not meet the "substantial impairment" burden required by the ADA in making a prima fade case of disability and discrimination. "Substantial impairment" includes an inability to function in caring for oneself, walking, seeing and learning.

Carol Cody was a quality assurance field nurse for Cigna Healthcare of St. Louis (Cigna). Her job required her to travel in the St. Louis metropolitan area, including the more dangerous parts of town. Cody claimed that she was intentionally assigned to these areas because they exacerbated her depression and anxiety. Cody took it up with her supervisor who she claimed, "blew her off." Soon after, Cody went to the executive director, told him she was seeing a psychologist and reiterated her concerns. The director called a meeting with Cody and the supervisor to discuss a potential solution.

Soon after, Cody stated, the supervisor confronted her about her contact with the director and told her she would "suffer the consequences. That same day, Cody found a sign on her desk reading "alms for the sick"

Soon after that, Cody was seen sprinkling salt in front of her desk to keep away evil spirits, staring off into space for an hour at a time, drawing pictures of sperm and talking about a gun.

When Cody arrived soon after for a meeting with the director, she had a noticeable bulge in her purse. The director, fearing a gun, called a security guard who deactivated Cody's access to the building. (It was later ascertained that she had not been carrying a gun.) The director offered Cody medical leave and a psychiatric evaluation, but she declined. She called the director later that day to resign.

Cody sued Cigna in district court claiming that she had been subjected to harassment in the workplace because of her depression. The district court dismissed the claim via summary judgment.

The 8th Circuit, on a review de novo, stated that to prove a prima facie case under the ADA, a plaintiff must show that she is disabled, qualified to perform the essential functions of her job and has suffered adverse employment action under circumstances arising from unlawful discrimination.

The court held that a mere showing that depression and anxiety have caused "great struggle" in daily activities, as Cody had shown, did not prove that Cody was indeed disabled. She therefore had not met the substantial impairment burden of the ADA and the summary judgment ruling was affirmed.