Duration of Impairment

The ADA does not impose a minimum duration requirement for an impairment to qualify as an actual disability. The effects of an impairment lasting or expected to last fewer than six months may be substantially limiting. Accordingly, a city should not deny an accommodation request solely because a condition is temporary, non-chronic, expected to improve, or expected to last fewer than six months.

In determining whether an individual has a disability, the relevant question is whether a physical or mental impairment substantially limits one or more major life activities. The term “substantially limits” must be construed broadly in favor of expansive coverage and generally should not require extensive analysis. Duration may be relevant to the individualized assessment, but an impairment need not be permanent, long-term, chronic, or of unknown duration to be substantially limiting.

An impairment that is episodic or in remission may also be a disability if it would substantially limit a major life activity when active.

The six-month concept applies only to the “transitory and minor” exception to coverage under the ADA’s “regarded as” prong. It does not establish a six-month minimum for actual-disability or record-of-disability coverage.