Grocery store's mask requirements survive ADA legal challenge

An interesting decision from the Western District of Pennsylvania, in Pletcher v. Giant Eagle. One of the plaintiff's, Josiah Kostek, sought a preliminary injunction against Giant Eagle grocery store claiming that its mask requirements violated the ADA. 

The plaintiff has been diagnosed with numerous mental impairments: "anxiety disorder; panic disorder; post-traumatic stress disorder; and, an adjustment disorder with mixed anxiety and a depressed mood." But, he failed to provide any medical records establishing that he could not wear a mask in the grocery store. Further, Giant Eagle allows shoppers to wear face shields instead of masks, and Kostek had no evidence that he was unable to wear a shield. 

The plaintiff managed to trip over the low bar of establishing a prima facie case. Of course, even if he had cleared that initial hurdle, Giant Eagle would still have an opportunity to present a defense - like, ya know, they're trying to avoid the further spread of a global pandemic that's already killed a few hundred thousand Americans. The Court did not directly rule on that issue, but sent a crystal clear message:

[T]he Court need not evaluate Giant Eagle's well-taken defenses that its face covering policy is a legitimate safety requirement during the COVID-19 pandemic and that Kostek presented a direct threat to the health and safety of others, including customers and employees.

I understand people's frustration with mask requirements, but it appears to be an uphill legal battle to challenge store policies requiring them.