Disability Law Index - Supreme Court Decisions

Definition of a Disability

Bragdon v. Abbott, 524 U.S 624 (1998).
Woman who was HIV+, but showed no symptoms, was covered by the ADA because she was substantially limited in the major life activity of reproduction.

Sutton v. United Airlines, 527 U.S. 471 (1999).
Murphy v. United Parcel Service, 527 U.S. 516(1999).
Albertson's, Inc. v. Kirkingburg, 527 U.S. 555 (1999).
Corrective devices or mitigating measures (i.e. eyeglasses, drugs, body's natural adaptation) must be considered in determining whether there is a disability. These cases have been rejected by the ADA Amendments Act.

Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (2002).
Factory worker's carpel tunnel syndrome (CTS) did not substantially limit in the major life activity of manual tasks (things she can do with her hands) when the manual tasks that she was limited in were specific to her job. Major life activities are supposed to be of central importance to everyday life. The proper inquiry then is to look at how CTS affected her ability to do manual tasks that are important to day-to-day living (outside of work). This case has been rejected by the ADA Amendments Act.

Employment

Wright v. Universal Maritime Service Corp., 525 U.S. 70 (1999).
Longshoreman was not required to arbitrate his ADA claim under a collective bargaining agreement (CBA) because any CBA requirement to arbitrate statutory claims must be particularly clear.

Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999).
Claiming that she was unable to work to collect social security disability benefits did not prevent an employee from also claiming that she could perform the essential functions of her job with reasonable accommodation for the purposes of the ADA. However, she had to give an explanation on the apparent discrepancy between the two claims when the case went back to the lower court.

Board of Trustees of University of Alabama v. Garrett, 531 U.S. 356 (2001).
State employees could not sue their employers for money damages under Title I of the ADA.

E.E.O.C. v. Waffle House, Inc., 534 U.S. 279 (2002).
Even though an employee had signed an agreement to arbitrate any dispute with his employer, the Equal Employment Opportunity Commission can still file a lawsuit on the employee's behalf.

US Airways, Inc. v. Barnett, 535 U.S. 391 (2002).
Reassigning an employee to another position is presumed to be an unreasonable accommodation if it interferes with an established seniority system.

Chevron U.S.A. Inc. v. Echazabal, 536 U.S. 73 (2002).
The Supreme Court upheld an Equal Employment Opportunity Commission regulation (interpreting the ADA) that allows an employer to discriminate against a worker because his disability on the job would pose a direct threat to the worker's own health. The controversy was that the actual text of the ADA only mentions that an individual should not pose a direct threat to the health or safety of others in the workplace.

Clackamas Gastroenterology Associates, P.C. v. Wells, 538 U.S. 440 (2003).
There was some confusion on whether the individual physician-owners of a doctor’s group qualified as an employee for the purposes of the ADA. The requirements of Title I apply when an employer has 15 or more employees. The Supreme Court listed a number of factors to consider before deciding whether someone was to be considered an employee or an employer.

Raytheon Co. v. Hernandez, 540 U.S. 44 (2003).
An employee who was fired for drug use reapplied for employment once he was rehabilitated but his employer refused citing its policy of not rehiring anyone that was fired for violating work rules. The policy was declared to be a legitimate non-discriminatory reason under a disparate treatment claim. However, the policy's disparate impact on persons with disabilities wasn't reviewed by the Court since the plaintiff didn't properly plead it.

Hosanna Tabor Lutheran Church and School v. E.E.O.C., __ U.S. __ (January 13, 2012).
Religious employer had a First Amendment right to fire its employee for threatening to pursue her legal options under the ADA. The Supreme Court agreed that there is a ministerial exception to employment discrimination laws which allows religious organizations to choose their ministers.

State and Local Governments

Pennsylvania Dept. of Corrections v. Yeskey, 524 U.S. 206 (1998).
Title II of the ADA applies to prisons since they are state operated.

Olmstead v. L.C., 527 U.S. 581 (1999).
Under Title II of the ADA, states are required to place people with mental disabilities in community settings rather than in institutions when: (1) the state's treatment professionals have determined that community placement is appropriate, (2) the transfer from institutional care to a less restrictive setting is not opposed by the affected individual, and (3) the placement can be reasonably accommodated, taking into account the resources available to the state and the needs of others with mental disabilities.

Buckhannon Bd. and Care Home, Inc. v. West Virginia Dept. of Health and Human Resources, 532 U.S. 598 (2001).
The ADA allows courts to award attorney fees and costs to the prevailing party. West Virginia changed its state law to comply with the ADA and Fair Housing Act making an ongoing lawsuit moot. The plaintiffs were not entitled to attorney fees because they weren't considered a prevailing party even though their lawsuit brought about the desired change.

Barnes v. Gorman, 536 U.S. 181 (2002).
Punitive damages may not be awarded in a private lawsuit under Title II of the ADA. Punitive damages are a money remedy that is designed to punish the lawbreaker through the pocketbook rather than compensate the victim.

Tennessee v. Lane, 541 U.S. 509 (2004).
Plaintiffs can sue a state for money damages under Title II of the ADA in cases that implicate the fundamental right of access to the courts.

United States v. Georgia, 546 U.S. 151 (2006).
Plaintiff can sue a state for money damages under Title II of the ADA for conduct that also violates the Fourteenth Amendment.

City and County of San Francisco v. Sheehan, __ U.S. __ (May 18, 2015).
The Supreme Court had originally granted certiorari on the question whether Title II of the ADA applied when a police officer faces an armed and dangerous individual. However, San Francisco argued instead that the plaintiff was not qualified for an accommodation so the Supreme Court remanded the case back to the lower courts.

Fry v. Napoleon Community Schools, __ U.S. __ (Feb. 22, 2017).
Plaintiff did not have to exhaust her administrative remedies under IDEA to pursue an ADA/504 case against her school for not allowing her to attend school with a service animal.

Public Accommodations

PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001).
Allowing Casey Martin to use a golf cart in golf tournaments was not a modification that would "fundamentally alter the nature" of the game despite the PGA's walking requirement and is mandated by Title III of the ADA.

Spector v. Norwegian Cruise Lines Ltd., 545 U.S. 119 (2005).
Title III of the ADA applied to foreign flagged ships in United States waters to the same extent they applied to American ships unless it interfered with the ship's internal affairs.