In Salmon v. Dade County School Board, 4 F. Supp. 2d 1157 (S.D. Fla. 1998), a case that was brought under the Americans with Disabilities Act of 1990 (ADA) (42 U.S.C. 12111(8) (1994)), the plaintiff a guidance counselor for the school board, suffered from a permanent partial disability of chronic lumbosacral strain, which caused back pain. After driving her car for long periods of time, she needed to stretch and rest her back. She complained that the heavy morning traffic exacerbated her back problems and asked to be transferred to a school that would afford her a shorter commute. In upholding the lower court's grant of summary judgment in favor of the board, which denied her request, the court held: "Plaintiff's commute to and from work is an activity that is unrelated to and outside of her job. While an employer is required to provide reasonable accommodations that eliminate barriers in the work environment, an employer is not required to eliminate those barriers which exist outside the work environment." Salmon , 4 F. Supp. 2d at 1163.