A federal judge dismissed a lawyer’s discrimination claims last month against a judge in El Paso County who allegedly failed to provide reasonable accommodations for her long COVID disability.

Andrea M. Hall sued District Court Judge Chad Miller and his judicial district, which encompasses El Paso and Teller counties, based on an April 2023 criminal trial in which she represented the defendant. Hall alleged that on the third day, she “suffered an exacerbation” of long COVID, which left her bedridden.

After having an allergic reaction to medication, Hall did not believe she could return to court the next day. She asked attorney Ingrid J. DeFranco to appear on her behalf.

DeFranco informed Miller of Hall’s condition, and Miller “immediately questioned the veracity of Ms. DeFranco’s representation,” wrote DeFranco, who also represented Hall in her civil lawsuit. Upon Miller’s order, Hall appeared in court in a wheelchair, where Miller told her that he would provide certain accommodations. He also asked Hall to provide proof of her disability, which was his regular practice for people affected by COVID-19.

Hall did not return for the trial, and Miller eventually granted a mistrial for unrelated reasons. However, Hall alleged that Miller “repeatedly accused Ms. Hall of grave misconduct and dishonesty, and publicly defamed her, at length, with a film crew present in the courtroom.” He also required her to have co-counsel if she represented the defendant in the second trial.

Hall filed claims under the Americans with Disabilities Act, seeking monetary damages and for the judicial district to comply with the ADA going forward.

The defendants moved to dismiss Hall’s claims, asserting Miller had judicial immunity for his actions as a judge. The Colorado Attorney General’s Office also argued that Hall’s allegations failed to show that she was a person with a disability under the ADA. Specifically, she had not described how her long COVID limited one or more “major life activities.”

“Here, the Complaint alleges that Hall was temporarily impaired after experiencing an allergic reaction to an unspecified medication, an insufficient fact to establish that she had a qualifying disability under the ADA,” the office wrote, adding that it was unclear whether Hall’s incapacitation was due to the medicine or to long COVID itself.

In a brief response, DeFranco acknowledged that Hall “did not expressly plead that she is substantially limited in one or more major life activities,” but “being bedridden substantially limits her ability to care for herself, perform manual tasks, eat, sleep, walk, stand, lift, bend, concentrate, think, write, interact with others and work as a trial lawyer.”

In a June 24 order, U.S. District Court Judge Nina Y. Wang agreed with the defendants that Hall’s allegations failed to show that she was a person with a disability with substantial limitations on major activities.

“In fact, the Complaint provides no information about what Ms. Hall’s symptoms actually were,” she wrote. “Nor does Ms. Hall provide any factual allegations about the duration of the impairment.”

Wang added that Hall’s allegations suggested the exacerbation of her long COVID was limited to April 2023, in which case her incapacitation was “an isolated event.”

“Absent additional meaningful details about Ms. Hall’s alleged condition, the Court cannot conclude that she has plausibly alleged a ‘substantial limitation’ that falls within the ADA’s ambit,” Wang wrote.

The case is Hall v. The Fourth Judicial District et al.