Employment Discrimination (ADA)
527 U.S. 471 (1999)
Study notes for Sutton v. United Air Lines, Inc.: professor notes, cold call prep, exam angles, and memory aids.
The ADA requires courts to consider mitigating measures when determining disabilities but does not consider a specific job disqualification as evidence of a general disability.
In Sutton v. United Air Lines, Inc., the Supreme Court interpreted the Americans with Disabilities Act (ADA) to establish that when assessing whether an individual has a disability, courts must take into account mitigating measures such as corrective lenses. Here, the Court determined that the plaintiffs, twin sisters with defective eyesight that could be corrected to 20/20, were not considered 'disabled' under the ADA when evaluating substantial limitation in a major life activity. This decision underscores the importance of defining disability in a way that reflects the capacity of individuals to function with the assistance of mitigating measures.
Additionally, the Court clarified that an employer's perception of an applicant as unable to perform a specific job does not, by itself, constitute a finding that the individual is regarded as disabled in terms of a major life activity. The ruling emphasizes a more stringent standard for what constitutes a disability under the ADA, focusing on how individuals are assessed in the scope of employment and the necessity of reinforcing an employer's need for legitimate job qualifications.
Consider lenses; it balances the definition of 'disability' with corrective capabilities.
| Case | Distinction |
|---|---|
| Southeastern Community College v. Davis | Southeastern focused on the essential functions of the job rather than the definition of disability, emphasizing job performance over mitigating measures. |
| Toyota Motor Manufacturing, Kentucky, Inc. v. Williams | Toyota addressed the substantial limitation standard and focused on the broader context of major life activities while Sutton honed in on specific job qualifications. |
| Chevron U.S.A. Inc. v. Echazabal | Chevron dealt with the concept of perceived disability in the context of safety concerns, while Sutton clarified that a specific job assessment does not imply a broader disability. |
The rule promotes a more realistic assessment of disabilities by acknowledging the positive impact of mitigating measures, allowing individuals to seek employment without discrimination based on perceived limitations.
Critics argue that focusing on mitigating measures can minimize the challenges faced by individuals with disabilities and could enable employers to set rigorous standards that disproportionately exclude qualified applicants.
This case often features on exams discussing ADA interpretations, particularly regarding disability assessments and mitigating measures, making it important for understanding the definition of 'disability' in employment law.