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Psychological Counseling May Constitute a Medical Examination Under the ADA

By Jillian M. Collins

Last week, in a case of first impression titled Kroll v. White Lake Ambulance Authority, the Sixth Circuit found that psychological counseling may qualify as a “medical examination” under the Americans With Disabilities Act (“ADA”), which forbids employers from requiring medical exams unless they are job-related. The Circuit Court vacated the lower court’s ruling in favor of White Lake Ambulance Authority on summary judgment in a discrimination case brought by Emily Kroll, a former employee.  Kroll had refused to attend psychological counseling mandated by White Lake after other employees reported concerns about Kroll’s well-being and White Lake received a complaint that Kroll had been screaming at a male acquaintance on her cell phone while driving an ambulance in emergency status with lights and sirens.  The district court found that such psychological counseling alone did not constitute a medical examination.

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