SUPREME COURT DECISIONS INTERPRETING THE
AMERICANS WITH DISABILITIES ACT**
Updated
September 17, 2002
National Council on Disability
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ACKNOWLEDGMENT
The National Council on Disability (NCD)
wishes to express its appreciation to
Professor Robert L. Burgdorf Jr. for
developing this analysis of Supreme Court
decisions interpreting the Americans with
Disabilities Act (ADA).
OVERVIEW OF ISSUES ADDRESSED BY THE COURT
IN ADA CASES
A.
Pennsylvania Department of Corrections v.
Yeskey, 524 U.S. 206 (1998).
ISSUE:
Whether Title II of ADA covers state
prisons and prisoners.
B.
Bragdon v. Abbott, 524 U.S. 624 (1998).
ISSUE:
Whether a dental patient's asymptomatic
HIV infection constituted a disability
under ADA, and whether the evidence in
the case was sufficient to defeat the
dentist's asserted defense that filling
the patient's cavity in his office would
in his professional judgment have
presented a direct threat to health or
safety.
C.
Wright v. Universal Maritime Service
Corp., 525 U.S. 70 (1998).
ISSUE:
Whether a general arbitration clause in a
collective bargaining agreement
requires an
employee to use the arbitration procedure
to address an alleged violation of ADA.
D.
Cleveland v. Policy Management Systems
Corp., 526 U.S. 795 (1999).
ISSUE:
The extent to which application for and
receipt of disability benefits precludes
a person with a disability from bringing
an
ADA
claim.
E.
Sutton v.
United Airlines,
527 U.S. 471 (1999).
ISSUES:
Whether, in a lawsuit brought by two job
applicants with severe nearsightedness
(myopia) to challenge an airline's
minimum vision requirement for global
pilots, corrective and mitigating
measures should be considered in
determining whether an individual is
disabled under ADA, and whether the
applicants had stated a valid claim that
the airline regarded them as disabled.
F.
Murphy v.
United Parcel Service,
527 U.S. 516 (1999).
ISSUES:
Whether the condition of a mechanic whose
high blood pressure was controlled by
medication should be considered in a
medicated or nonmedicated state in
determining whether he has a disability,
and whether an employer's belief that the
employee's high blood pressure prevented
him from satisfying a DOT health
requirement for driving commercial
vehicles constituted regarding him as
having a disability under ADA.
G.
Albertson's, Inc. v. Kirkingburg,
527 U.S. 555 (1999).
ISSUES:
Whether having monocular vision
constitutes per se disability under ADA
and whether a DOT safety regulation
justified an employer's visual-acuity job
qualification standard, even though the
DOT regulation contained a waiver
provision under which the standard could
be waived in an individual case.
H.
Olmstead
v. L.C.,
527 U.S. 581 (1999).
ISSUES:
Whether ADA requires a state to place
people with mental disabilities in
community settings rather than in
institutions when the state's treatment
professionals have determined that
community placement is appropriate, and
what standard is to be applied in
assessing a state's assertion of a
fundamental alteration defense to the
obligation to afford such community
placement.
I.
Board of
Trustees of the University of Alabama v.
Garrett,
531 U.S. 356 (2001).
ISSUE:
Whether the Eleventh Amendment bars
employees of a state from recovering
monetary damages from the state for
violations of Title I of
ADA.
J.
Buckhannon Board and Care Home, Inc. v.
W. Va. Dep't of Health and Human Res.,
532 U.S. 598, 121 S.Ct. 1835 (2001).
ISSUE:
Whether federal statutes that allow
courts to award attorney's fees and costs
to the "prevailing party" authorize
awards of fees to parties whose lawsuits
brought about voluntary changes in the
defendants' conduct but did not result in
judgments on the merits or court-ordered
consent decrees.
K.
PGA Tour,
Inc. v. Martin,
532 U.S. 661, 121 S.Ct. 1879 (2001).
ISSUES:
Whether Title III of ADA protects
qualified entrants with disabilities
participating in professional golf
tournaments, and whether allowing a
golfer with a disability to use a golf
cart when all other competitors must walk
would "fundamentally alter the nature" of
the tournaments.
L.
Toyota
Motor Manufacturing, Kentucky, Inc. v.
Williams,
122 S.Ct. 681 (2002).
ISSUE:
whether a worker's carpal tunnel syndrome
and other painful conditions of
her wrists,
elbow, and shoulders substantially
limited her in the major life activity of
performing manual tasks and thus
constituted a disability under the ADA.
M.
Equal
Employment Opportunity Commission v.
Waffle House, Inc.,
122 S.Ct. 754 (2002).
ISSUE:
whether an agreement between an employer
and an employee to arbitrate any
employment-related dispute or claim bars
the Equal Employment Opportunity
Commission (EEOC) from pursuing
victim-specific remedies, such as back pay,
reinstatement, and damages, against the
employer for allegedly violating the
ADA.
N.
U.S.
Airways, Inc. v. Barnett,
122 S.Ct. 1516 (2002).
ISSUE:
whether the rights of a worker with a
disability who seeks assignment to a
particular position as a reasonable
accommodation under the
ADA
take precedence over other workers'
rights to bid for the position under the
employer's seniority system.
O.
Chevron
U.S.A. Inc. v. Echazabal,
122 S.Ct. 2045 (2002).
ISSUE:
whether the Equal Employment Opportunity
Commission regulation that allows
employers to refuse to hire applicants
because their performance on the job
would endanger their health due to a
disability is permitted under the ADA.
P.
Barnes v.
Gorman,
122 S.Ct. 2097 (2002).
ISSUE:
whether punitive damages may be awarded
in private causes of action brought under
either Title II of the ADA or under
Section 504 of the Rehabilitation Act of
1973.
Overview
SOME SIGNIFICANT IMPLICATIONS OF THE
DECISIONS |
