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J Am Acad Psychiatry Law. 2012;40(4):553-61.

The implications of the ADA Amendments Act of 2008 for residency training program administration.

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Butler Hospital, 345 Blackstone Boulevard, Providence, RI 02906, USA.


The Americans with Disabilities Act (ADA) is rarely invoked by medical residents in training. Dr. Martin Jakubowski, a family medicine resident with Asperger's disorder, was dismissed for communicating poorly with patients, peers, and supervisors and for issuing dangerous medical orders. In an attempt to become reinstated, he sued under the ADA (Jakubowski v. The Christ Hospital), arguing that the program had failed to make reasonable accommodation for his disability. The Sixth Circuit Court of Appeals ruled in favor of the hospital, finding that although the doctor was disabled under the ADA, he had failed to demonstrate that he was otherwise qualified for the position. This article comments on the ADA Amendments Act of 2008, the Equal Employment Opportunity Commission (EEOC) guidelines from 2011 and their application to medical residency training, and the Accreditation Council for Graduate Medical Education (ACGME) core competencies as essential job functions.

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