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Manufacturing, Kentucky , Inc. v. Williams. Sutton, 119 S.Ct. 2139 (1999), superseded by statute, ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553; Williams, 122 S.Ct. 681 (2002), superseded by statute, ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. In Sutton, the Court held that the mitigating effects of medications had to be taken into account in determining whether or not a person was “substantially limited” in performing a major life activity. Sutton, 119 S.Ct. at 2146. In Williams, the Court held that the phrase “substantially limited” precluded impairments that interfered with major life activities in only minor ways from qualifying as “disabilities” under the ADA. Williams, 122 S.Ct. at 691. Williams also noted that major life activities are those activities which are of central importance to daily life, such as walking, seeing, and hearing. Id.

The district court found that, although Carmona had presented sufficient evidence that he had an impairment that affected his major life activities of sleeping, standing, and walking, he had not presented sufficient evidence that this impairment was substantially limiting. The district court reached its conclusion in part because it found that our holding in Waldrip v. General Electric Co., 325 F.3d 652 (5th Cir. 2003), controlled Carmona’s case. The district court interpreted Waldrip as standing for the proposition that impairments that cause temporary, intermittent limitations of major life activities are not substantially limiting as a matter of law.

Shortly before Carmona’s case went to trial, Congress amended the ADA in order to correct what it viewed as an overly restrictive interpretation of the statute’s terms that had been adopted by the Supreme Court in Sutton and Williams. See ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. These amendments would be very favorable to Carmona’s case if

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