An endometriosis workplace accommodation lawsuit can succeed under the Americans with Disabilities Act when symptoms are severe enough to substantially limit major life activities. That is the takeaway from Proffitt v. North Carolina Department of Public Safety, a 2025 federal case believed to be the first in North Carolina — and among the first nationally — in which a court allowed an endometriosis-based ADA claim to survive summary judgment and head toward trial. The state settled before that trial happened.
The North Carolina Case
Christian “Cece” Worley was a Juvenile Court Counselor Trainee for the North Carolina Department of Public Safety. In May 2022, she told her supervisors she had endometriosis and asked to telework on the first day of her menstrual cycle each month. She also asked for time off for fertility-related medical appointments. The state already had a formal statewide teleworking policy on the books.
By her account, which the court credited at summary judgment, her supervisors refused. Her boss told her she was taking “too much sick time” and that it showed “poor work ethic.” The Chief Court Counselor for District 16 said accommodating her would mean he’d “have to do the same for every woman” in the office. She was told there would be “absolutely not” any accommodations, and that raising the issue again would bring “disciplinary action up to and including termination.” No interactive process — the back-and-forth dialogue the ADA expects when an employee requests accommodations — ever took place. Worley gave a week’s notice and left on May 19, 2022, later claiming constructive discharge.
She filed in the U.S. District Court for the Eastern District of North Carolina in June 2023 and litigated pro se while attending law school, after multiple attorneys told her the law here was “not fully developed” and “too interpretive.”
On July 18, 2025, U.S. Magistrate Judge Robert T. Numbers II issued a memorandum finding that Worley’s symptoms — being bedridden at least one day per month with pain and vomiting — were severe enough to constitute a disability under the ADA. The court relied on her testimony about missed college classes, doctors’ notes documenting absences, online posts describing her symptoms, and her account of being “paralyzed in bed” for a full day each month. Six claims were allowed to move forward: failure to accommodate, disability discrimination, wrongful discharge, hostile work environment, and FMLA interference and retaliation. Only her Title VII sex discrimination claim was recommended for dismissal, because she had not identified a similarly situated male employee treated better. District Judge Terrence Williams Boyle adopted the recommendation in full on September 30, 2025.
The case settled on December 19, 2025. Worley received what has been described as a near six-figure monetary settlement, and the Department of Public Safety agreed to implement department-wide ADA training for management staff.
What the Ruling Does and Doesn’t Establish
The court did not declare endometriosis a disability across the board. Judge Numbers described the analysis as “complex and fact-specific.” Federal courts have gone both ways on similar questions. In Social Security disability cases, some judges have credited evidence of repeated surgeries, hospitalizations, and incapacitating pain; others have denied claims where the diagnosis lacked objective medical evidence, where symptoms were described as intermittent and controllable with medication, or where the claimant kept working.
What Proffitt does give future plaintiffs is a concrete federal precedent for the argument that severe endometriosis can meet the ADA’s “substantially limits a major life activity” threshold. That is the exact bar the statute sets, and it does not list qualifying conditions.
The EEOC’s Equinox Case
A second recent data point comes from federal enforcement. In December 2024, the Equal Employment Opportunity Commission sued Equinox Holdings, alleging that one of its Washington, D.C., locations refused to hire an applicant named Rahdia Green after she disclosed an endometriosis diagnosis and asked to reschedule a second-round interview because of severe menstrual cramps. The EEOC cited a text from an Equinox hiring manager who called Green’s qualifications “excellent” but wrote that she was rejected “[o]nly because [of] the concern in the future if your absence may occur due to your month cycle.”
The agency brought dual claims: ADA disability discrimination, and Title VII sex discrimination on the theory that adverse treatment based on menstruation is sex-based. Equinox settled in June 2025 under a two-year consent decree requiring the company to pay $48,000 to Green, implement new anti-discrimination and accommodation policies, provide ADA and Title VII training at its five D.C.-area locations, and submit to federal monitoring.
What a Reasonable Accommodation Can Look Like
The ADA does not prescribe a specific list of accommodations for any condition. What counts as “reasonable” depends on the job, the employer’s resources, and the employee’s particular symptoms. For endometriosis, accommodations identified by disability rights organizations and medical groups include:
- Flexible scheduling
- Remote work on symptomatic days
- Additional or extended breaks
- Access to a private space for rest or pain management
- Ergonomic workspace adjustments
- Additional sick leave during flare-ups
The process typically starts with a formal written request supported by medical documentation. Employees are advised to describe how their symptoms affect their ability to do the job and what specific adjustments would help. The employer is then expected to engage in the interactive process — a good-faith dialogue about what will work for both sides. Refusing to engage in that dialogue at all, as Worley alleged happened to her, is itself a potential ADA violation.
Notice: The Part of Proffitt That Cuts Both Ways
One detail from the ruling matters for anyone planning to request an accommodation. The court did not grant summary judgment to Worley on her failure-to-accommodate claim. Judge Numbers found the record unclear on whether she had given her employer adequate notice of how severe her condition was, writing that while she told supervisors about her menstrual pain, she “did not adequately disclose the impact that the pain had on her,” such as the fact that it left her bedridden.
The practical implication for an employee making a request: describing the diagnosis is not enough. The request should spell out how symptoms limit specific activities — being unable to get out of bed, vomiting, missing full workdays — because that impact is what triggers the ADA’s protection in the first place. Documentation from a treating physician that speaks to functional limitations, not just the diagnosis, gives an employer less room to claim it did not know what it was being asked to accommodate.
Where This Leaves Employees
Two recent federal outcomes — a magistrate’s ruling and settlement in Proffitt, and the EEOC’s consent decree with Equinox — show that severe endometriosis can support both a hiring-stage discrimination claim and an accommodation claim against an existing employer. Neither case makes the outcome automatic. Both turned on specific facts: documented severity in Worley’s case, and a manager’s written admission in Green’s. An employee considering a similar claim should expect the same fact-specific inquiry, and should build the record accordingly before, during, and after making the accommodation request.