An employee who experienced temporary cold-like symptoms such as headache, shortness of breath, and sore throat after being exposed to colognes or perfumes does not have a disability under the Americans with Disabilities Act, a federal district court rules. In granting summary judgment for the employer, the court said that although the employee was temporarily restricted in her ability to perform activities such as breathing and seeing when her throat constricted and eyes watered after exposure to fragrances, such “intermittent flare-ups” do not establish that an impairment is a disability. The court also noted that the employee considered herself disabled only when exposed to perfume or fragrances, and had “never been hospitalized for this condition.” Robinson v. Morgan Stanley Dean Witter.