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Love v. Law School Admission Council, Inc., 513 F.Supp.2d 206, 225 Ed. Law Rep. 715, 34 NDLR P 120

Facts

Jonathan Love, a 25-year-old MBA student, claimed he suffered from ADHD and a learning disability, which he argued warranted accommodations for the LSAT. He initially took the LSAT in 2003 without accommodations and scored 150, which was average. After requesting accommodations for a subsequent LSAT, LSAC denied his request, stating that the documentation did not demonstrate a substantial limitation. Love's subsequent legal action followed a series of denied requests for accommodations.

Plaintiff alleges that he suffers from Attention Deficit Hyperactivity Disorder (“ADHD”) Combined Type. He alleges that he also suffers from a learning disability affecting academic fluency and processing speed. Plaintiff first took the LSAT without accommodation in October 2003. He received a score of 150 (out of a possible 180), a score that fell within the national average range.

Issue

Did Jonathan Love's ADHD substantially limit him in performing a major life activity, thereby entitling him to accommodations under the ADA for the LSAT?

Did Jonathan Love's ADHD substantially limit him in performing a major life activity, thereby entitling him to accommodations under the ADA for the LSAT?

Rule

Under the ADA, a disability is defined as a physical or mental impairment that substantially limits one or more major life activities.

Under the ADA, a disability is defined as a physical or mental impairment that substantially limits one or more major life activities.

Analysis

The court analyzed the evidence presented, including expert testimonies regarding Love's ADHD and its impact on his daily life. It concluded that while Love had ADHD, the evidence did not sufficiently demonstrate that it substantially limited his ability to perform major life activities, such as learning or working, which is necessary to qualify for accommodations under the ADA.

Based upon the evidence and testimony presented at trial, we make the following Findings of Fact and Conclusions of Law.

Conclusion

The court held that Jonathan Love was not entitled to accommodations for the LSAT under the ADA because his ADHD did not substantially limit him in performing a major life activity.

Following a bench trial, the District Court, J. Surrick, J., held that student's ADHD did not substantially limit him in performing a major life activity, and thus, student was not entitled to accommodations under the ADA.

Who won?

Law School Admissions Council (LSAC) prevailed because the court found that Love's ADHD did not meet the criteria for a disability under the ADA.

Defendant LSAC is a private non-profit entity that administers the LSAT, an exam that is required for admission to all accredited law schools in the United States.

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