Introduction

In the landmark case Jessica Ramsay v. National Board of Medical Examiners, 968 F.3d 251 (3d Cir. 2020), the United States Court of Appeals for the Third Circuit affirmed a preliminary injunction requiring the National Board of Medical Examiners (NBME) to provide Jessica Ramsay, a medical student diagnosed with dyslexia and Attention Deficit Hyperactivity Disorder (ADHD), with additional accommodations during her United States Medical Licensing Examination (USMLE). The core issue revolved around whether Ramsay's disabilities qualified her for accommodations under the Americans with Disabilities Act (ADA), and whether the Board's denial of her requests constituted a violation of her rights under the ADA.

The parties involved included Jessica Ramsay, the appellant, and the National Board of Medical Examiners, the defendant. The District Court initially granted a preliminary injunction favoring Ramsay, which the Board subsequently appealed. This case underscores significant considerations regarding disability accommodations in high-stakes professional examinations and sets a precedent for how such cases might be adjudicated in the future.

Summary of the Judgment

The District Court ruled in favor of Jessica Ramsay, issuing a preliminary injunction that mandated the NBME to provide her with double the testing time for USMLE Steps 1, 2 Clinical Knowledge (CK), any written or reading portions of Step 2 Clinical Skills (CS), and Step 3. Ramsay had initially been denied accommodations despite presenting substantial evidence of her disabilities, including medical diagnoses, academic records, and expert evaluations.

The Board had countered Ramsay's requests by presenting its own expert opinions, which concluded that Ramsay was not "substantially limited in functioning" to warrant accommodations. However, the District Court found that Ramsay's experts provided more persuasive evidence, demonstrating that her dyslexia and ADHD significantly impaired her reading, writing, and processing abilities compared to the general population.

Upon appeal, the Third Circuit Court of Appeals reviewed the District Court's decision and ultimately affirmed the preliminary injunction. The appellate court upheld the District Court's findings, affirming that Ramsay had a reasonable likelihood of success on the merits of her ADA claim and that irreparable harm would likely ensue without the injunction.

Analysis

Precedents Cited

The judgment extensively cited and built upon existing ADA precedents and regulations. Key precedents include:

• Pryer v. C.O. 3 Slavic, 251 F.3d 448 (3d Cir. 2001) – emphasized that ADA disability determinations should be based on whether an impairment substantially limits a major life activity compared to the general population.
• Chafin v. Chafin, 568 U.S. 165 (2013) – clarified that cases remain justiciable if the parties continue to have a personal stake in the outcome, which was pertinent to maintaining the case's viability despite Ramsay passing Step 1 after the preliminary injunction.
• Equal Employment Provisions, 76 Fed. Reg. at 17,009; Title II and Title III Regulations, 81 Fed. Reg. at 53,230 – provided regulatory framework for assessing disabilities under the ADA, which the court adhered to in evaluating Ramsay's condition.

These precedents influenced the court's balanced approach in evaluating disability claims, ensuring that Ramsay's condition met the statutory requirements of the ADA and that the Board's actions were scrutinized under established legal standards.

Legal Reasoning

The court employed a meticulous legal reasoning process grounded in ADA definitions and regulatory interpretations. Central to the court's decision was the interpretation of "disability" under the ADA, which is defined as a "physical or mental impairment that substantially limits one or more major life activities." Ramsay's dyslexia and ADHD were scrutinized to determine if they significantly impeded her major life activities, particularly reading, writing, and processing information—core components of the USMLE.

The court deferred to the District Court's assessment, which favored Ramsay's expert testimonies over those presented by the Board. This deference was justified based on the personalized evaluations provided by medical professionals who had directly interacted with Ramsay, as opposed to the Board's reliance on record-only reviews. The appellate court underscored that individualized assessments are crucial in disability determinations and that the District Court appropriately weighed the evidence in favor of Ramsay.

Additionally, the court analyzed the four-factor test for preliminary injunctions established under 28 U.S.C. § 1292(a)(1), which includes the likelihood of success on the merits, irreparable harm, balance of equities, and public interest. Ramsay demonstrated a reasonable probability of prevailing on her ADA claim, established that her inability to receive accommodations would result in irreparable harm (potential dismissal from medical school), and showed that the balance of equities tipped in her favor without significantly harming the Board's interests or the integrity of the USMLE.

Impact

This judgment has profound implications for future cases involving disability accommodations in professional licensing and certification examinations. It reinforces the judiciary's commitment to upholding ADA protections, especially in high-stakes academic and professional settings. The ruling clarifies that:

• Individuals with documented disabilities such as ADHD and dyslexia are entitled to reasonable accommodations, provided they can substantiate how these impairments substantially limit major life activities.
• Testing bodies must carefully evaluate accommodation requests, giving substantial weight to personalized medical evaluations and documented histories of accommodations.
• Preliminary injunctions can be a viable remedy to prevent irreparable harm in situations where immediate action is necessary to uphold ADA compliance.

This precedent ensures that educational and professional institutions are held accountable for providing necessary accommodations, thereby promoting inclusivity and fairness in competitive environments.

Complex Concepts Simplified

Americans with Disabilities Act (ADA)

The ADA is a civil rights law that prohibits discrimination against individuals with disabilities in all areas of public life, including jobs, schools, transportation, and all public and private places that are open to the general public.

Disability Under the ADA

Under the ADA, a disability is defined as a physical or mental impairment that substantially limits one or more major life activities. This includes conditions like dyslexia and ADHD, provided they significantly hinder activities such as reading, writing, and processing information compared to the average person.

Preliminary Injunction

A preliminary injunction is a temporary court order that prevents a party from taking a particular action until a final decision is made in the case. It is granted when there is a reasonable chance the plaintiff will win the case, and without the injunction, the plaintiff would suffer irreparable harm.

Substantial Limitation

This term refers to the degree to which a disability restricts a person’s ability to perform major life activities. For a condition to be considered a disability under the ADA, it must significantly impede these activities compared to the general population.

Balance of Equities

In the context of preliminary injunctions, this refers to weighing the potential harm to the plaintiff if the injunction is not granted against the potential harm to the defendant if it is granted. The court assesses which harm is greater and more significant.

Conclusion

The Third Circuit's affirmation in Jessica Ramsay v. National Board of Medical Examiners underscores the judiciary's role in enforcing ADA protections within professional and academic spheres. By validating Ramsay's right to receive necessary accommodations, the court not only reinforced the importance of accessibility and fairness in examinations but also set a clear precedent for how similar cases should be adjudicated in the future. This decision emphasizes that individuals with disabilities must be afforded the necessary support to compete on an equal footing, thereby advancing the broader societal goal of inclusivity and nondiscrimination.