The Oyez Project: Civil Rights Issues - Handicapped, Rights of Decisions

Albertsons Inc. v. Kirkingburg

Are all individuals with vision problems of any degree "disabled" under the Americans with Disabilities Act and, therefore, subject to its protections?

No. In a unanimous decision, the Court held that not all individuals who suffer some sort of physical difficulty are per se "disabled" under the ADA. Instead, those who believe they suffer from a disability must prove their claim on a case-by-case basis by showing that their alleged disability substantially impacts on a major life activity. Moreover, such impact could be mitigated by the availability of artificial aids, such as medications or technical devices, and the body's own corrective measures. As such, Kirkingburg's visual limitation was not reflexively covered under the ADA and so his challenge was inappropriate.

Alexander v. Choate

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Barnhart v. Thomas

Are persons eligible for Social Security disability benefits if they are still able to perform their jobs, but the jobs no longer exists in meaningful numbers in the national economy?

No. In a unanimous opinion authored by Justice Antonin Scalia, the Court held that the SSA's decision had been a reasonable interpretation of the statute and was therefore entitled to deference under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837. Justice Scalia wrote, "The proper Chevron inquiry is not whether an agency construction can give rise to undesirable results... but whether... the agency construction is reasonable. Here, the SSA's authoritative decision satisfies that test."

Barnhart v. Walton

Does the term "inability," in the Social Security Act, include a 12 month requirement, such that the inability must last, or must be expected to last, for at least 12 months? Is the term "expected to last" applicable only when the "inability" has not yet lasted 12 months?

Yes and yes. In a 9-0 opinion delivered by Justice Stephen G. Breyer, the Court held that the Social Security Administration's interpretations of the statute fell within its lawful interpretative authority. Justice Breyer noted that the Administration has determined in both its formal regulations and its interpretation of those regulations that an "inability" must last the same amount of time as an "impairment," or last or be expected to last not less than 12 months. "The statute's complexity, the vast number of claims that it engenders, and the consequent need for agency expertise and administrative experience lead us to read the statute as delegating to the Agency considerable authority to fill in, through interpretation, matters of detail related to its administration," concluded Justice Breyer.

Bowen v. American Hospital Assn.

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Bowen v. City Of New York

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Bragdon v. Abbott

Can a physician refuse or alter care of an HIV-positive patient without violating the equal treatment stipulations of the Americans with Disabilities Act of 1990 (ADA)?

No. In a 5-to-4 opinion, the Court held that although the ADA does not force care-givers to treat an "individual [who] poses a direct threat to the health or safety of others," it also prohibits discrimination against any individual "on the basis of disability in the enjoyment of the services of any place of public accommodation by any person who operates [such] a place." The Court then reasoned that since HIV "substantially limits" major life activities, such as reproduction, the infection is a "disability" that entitles its victims to ADA protections. Having said this, however, the Court concluded that only care-givers can determine if treating an HIV-positive individual would constitute a "direct threat" to themselves or others. Therefore, the Court remanded for further risk assessment based on objective medical evidence or risk.

Burlington School Comm. v. Mass. Dept. Of Ed.

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Cedar Rapids Comm. Sch. Dist. v. Garret F. and Charlene F.

Do schools that receive federal funding under the Individuals with Disabilities Education Act have to pay for one-on-one nursing assistance for certain of their disabled students?

Yes. In a 7-to-2 decision, the Court held that if the services in question are "related" to keeping the disabled child in school and able to access educational opportunities available to others IDEA funded school districts must provide such services. The Court added that although the nature and cost of providing certain IDEA "related services" is not determinative of whether their financial burdens must be met, potential financial burdens shall inform any decision governing their provision. In the present case, the benefits of providing Garret with his needed care outweighed the burdens.

Chevron U.S.A., Inc. v. Echazabal

Does the Americans with Disabilities Act of 1990 permit the Equal Employment Opportunity Commission's regulation that allows the defense that a worker's disability on the job would pose a direct threat to his health?

Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that the ADA did not preclude the EEOC's regulation allowing the harm-to-self defense. The Court reasoned that deference applied to the regulation because it made sense of the statutory defense for qualification standards that are job-related and consistent with business necessity. The Court also found that the risk of violating the Occupational Safety and Health Act of 1970 (OSHA) was enough to show that the regulation was permissible. "Although there may be an open question whether an employer would actually be liable under OSHA for hiring an individual who knowingly consented to the particular dangers the job would pose to him, there is no denying that the employer would be asking for trouble: his decision to hire would put Congress's policy in the ADA, a disabled individual's right to operate on equal terms within the workplace, at loggerheads with the competing policy of OSHA, to ensure the safety of 'each and 'every worker," wrote Justice Souter.

City of Edmonds v. Oxford House

Does the City of Edmonds' zoning code provision covering areas zoned for single-family dwelling units -- which defines family as persons related by genetics, adoption, or marriage, or a group of five or fewer unrelated persons -- qualify for exemption from the Fair Housing Act?

No. In a 6-3 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Edmonds' zoning code definition of the term "family" is not a maximum occupancy restriction exempt from the FHA. Noting that it was designed to foster the family character of a neighborhood, Justice Ginsburg reasoned that the provision was a family composition rule and was not a maximum occupancy restriction exempt from FHA scrutiny because, while it capped the number of unrelated persons allowed to occupy a single-family dwelling at five, it did not cap the total number of people permitted to live in such a dwelling. Justice Clarence Thomas wrote a dissenting opinion, which was joined by Justices Antonin Scalia and Anthony M. Kennedy.

Cleveland v. Policy Management Systems

Does application for, and receipt of, Social Security Disability Insurance reflexively bar alleged victims of discrimination from simultaneously pursuing a claim against their former employers under the 1990 Americans with Disabilities Act?

No. In a unanimous decision, the Court held that SSDI and ADA claims do not conflict in such a way as to automatically bar anyone from raising them jointly. The Court explained that when determining SSDI eligibility, the significant ADA question of whether someone would have been capable of performing their job if "reasonable accommodations" had been made by their employer, is not considered. As such, the "reasonable accommodation" issue is left open for resolution during an ADA claim. The Court added that any inconsistencies between ADA and SSDI claims are even more trivial if the ADA claim is brought prior to an actual SSDI award - as Cleveland did. Even in clear cases, where a contradiction would seem to lie between the two claims, alleged victims must still have the opportunity to present their cases.

Dellmuth v. Muth

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Department Of Transp. v. Paralyzed Veterans

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Florence County School District Four v. Carter

May a court order reimbursement for parents who withdrew their child from a public school providing an inappropriate education under the Individuals with Disabilities Education Act and put the child in a private school that is in substantial - but not complete - compliance with the act?

Yes. In an opinion written by Justice Sandra Day O'Connor, the Supreme Court unanimously held that parents have a right to withdraw their child from a public school providing an inappropriate education under the meaning of IDEA and enroll them in a private school, as long as the private school provides an "appropriate" education. The Court further held that the specific requirements of the Act need not be met when a student is placed in a private school by his or her parents, because the IDEA requirements were not intended to apply to parental placements.

Hendrick Hudson Dist. Bd. Of Ed. v. Rowley

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Honig v. Doe

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Irving Independent School Dist. v. Tatro

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Murphy v. United Parcel Service

Is high blood pressure a "substantial impairment" that might limit one's life activities to such an extent as to justify their being called "disabled" and, therefore, entitled to protection under the 1990 Americans with Disabilities Act?

No. In a 7-to-2 decision, the Court held that the determination of whether one is "disabled" under the ADA must be made in light of available mitigating circumstances. In the present case, the Court did not find Murphy "disabled" since he could function normally with the help of blood pressure medication. Moreover, although no longer able to serve as a commercial truck driver for UPS, Murphy could still work as a mechanic - the position for which he was officially hired. The Court concluded that in order to be designated as "disabled" an employee must be unable to perform more than just one task.

Olmstead v. Zimring

Should financial constraints entirely determine whether states comply by the 1990 Americans with Disabilities Act guidelines concerning community treatment programs for the mentally handicapped?

No. In a 6-to-3 decision, the Court began by noting that the question in this case was still ripe even though the two women at issue were placed in communal care since their controversies were initiated. The Court then found that the ADA required the placement of mentally disabled patients in "integrated settings" when they are medically cleared for such settings, they themselves express a desire for such settings, and the resources for such a transfer are available. The Court added that financial constraints might be significant if the state can show that allocation of resources to one patient will cause harm to others. The case was remanded for a better analysis of GRH spending priorities.

Pennhurst State School v. Halderman

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Pennsylvania Department of Corrections v. Yeskey

Did the Pennsylvania Department of Corrections' refusal to allow a prison inmate to participate in a motivational boot camp, because of the inmate's history of hypertension, violate Title II of the Americans with Disabilities Act of 1990 (ADA) prohibiting disability-based discrimination against qualified individuals?

Yes. In a unanimous opinion, the Court held that under the ADA no "public entity" may discriminate against qualified disabled individuals due to their disability. Moreover, the Court stated that the ADA's protections extended to cover prison inmates as well as any other liberated citizen.

PGA Tour v. Martin

Does the Americans with Disabilities Act of 1990 provide access to professional golf tournaments by a qualified entrant with a disability? May a disabled contestant be denied the use of a golf cart because it would "fundamentally alter the nature" of the tournaments to allow him to ride when all other contestants must walk?

Yes and no. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that Title III of the ADA, by its plain terms, prohibits the PGA from denying Martin equal access to its tours on the basis of his disability and that allowing Martin to use a cart, despite the walking rule, is not a modification that would "fundamentally alter the nature" of the game. "The purpose of the walking rule is... not compromised in the slightest by allowing Martin to use a cart," wrote Justice Stevens, noting Martin's fatiguing disability. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented.

Pittston Coal Group v. Sebben

No details yet.

Raytheon v. Hernandez

Does the Americans with Disabilities Act permit employers to refuse to rehire job applicants because of prior workplace rule infractions related to drug or alcohol addiction?

Yes. The Court unanimously held that an employer may refuse to rehire an employee who was terminated in connection with drug or alcohol-related incidents as long as the refusal is based on a policy of not rehiring employees who previously violated workplace rules rather than on the worker's addiction. That is, an employer may refuse to hire someone who was terminated for coming to work under the influence, but may not refuse to hire someone whose previous addiction did not result in any workplace rule infractions. Justices David Souter and Stephen Breyer took no part in this case.

Schaffer v. Weast

Do the parents or school system bear the burden of proof in disputes over a child's individualized education program under the Individuals with Disabilities Education Act?

In a 6 to 2 ruling, the Supreme Court held that the party bringing the suit bears the burden of proof, whether that party is the parents or the school system. In the majority opinion, Justice Sandra Day O'Connor wrote that "absent some reason to believe that Congress intended otherwise, ... we will conclude that the burden of persuasion lies where it usually falls, upon the party seeking relief."

Spector v. Norwegian Cruise Line Ltd.

Does Title III of the Americans with Disabilities Act apply to foreign-flagged cruise ships in U.S. waters?

Yes. The Court held 6-3 that Title III applied to foreign-flag cruise ships in U.S. waters. Justice Kennedy delivered the Court's controlling opinion, which held that Title III did not apply to foreign ships' internal affairs, because there was no "clear congressional statement" showing an intent to do so. A clear statement was necessary before a general law could interfere with a foreign-vessel's internal affairs. Title III's own limitations, however, prevented the statute from imposing requirements that would have threatened safety on the ship or conflicted with international obligations. If Title III were to impose certain requirements, such as major structural modifications, the clear statement rule could bar such an interference.

Sutton v. United Air Lines

(1) Should the determination of disability under 42 U.S.C. Section12102(2)(A) be made without reference to corrective measures that mitigate the impairment? (2) Is poor vision regarded as an impairment that substantially limits the Suttons in a major life activity?

No and no. Determination of disability under the ADA should be made in reference to an individual's ability to mitigate his or her impairment through corrective measures. This reading is in harmony with the statutory language and history of the ADA because (1) the phrase "substantially limits" requires consideration of present, not future or hypothetical, impairment; (2) the ADA calls for individualized assessments of impairment; and (3) Congress found that approximately 43 million Americans were disabled, a number that would be far too low if Congress had meant to include all those with correctable impairments. Also, assuming without deciding that working is a major life activity for purposes of the ADA, poor vision cannot be regarded as a substantially limiting impairment because it has only foreclosed the Suttons from pursuing work as "global airline pilots," not from numerous other positions in the aviation industry.

Tennessee v. Lane

Did the Americans with Disabilities Act violate the sovereign immunity doctrine of the 11th Amendment when, based on Congress's 14th Amendment enforcement powers of the Due Process clause, it allowed individuals to sue states for denying them services based on their disabilities?

No. In a 5-to-4 opinion written by Justice John Paul Stevens, the Court held that Congress had sufficiently demonstrated the problems faced by disabled persons who sought to exercise fundamental rights protected by the Due Process clause of the 14th Amendment (such as access to a court). The Court also emphasized that the remedies required from the states were not unreasonable - they just had to make reasonable accommodations to allow disabled persons to exercise their fundamental rights. Because Title II was a "reasonable prophylactic measure, reasonably targeted to a legitimate end," and because Congress had the authority under the 14th Amendment to regulate the actions of the states to accomplish that end, the law was constitutional.

Toyota Motor Mfg v. Williams

Did the Court of Appeals use the proper standard in determining whether an employee was disabled under the ADA due to carpel tunnel syndrome by showing that her manual disability involved a class of manual activities affecting the ability to perform tasks at work?

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that the Court of Appeals did not apply the proper standard in making its determination because it analyzed only a limited class of manual tasks and failed to ask whether Williams's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives. The Court also reasoned that for the purposes of the ADA, an impairment's impact must also be permanent or long-term. "Given large potential differences in the severity and duration of the effects of carpal tunnel syndrome, an individual's carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA," wrote Justice O'Connor for the Court.

US Airways v. Barnett

Does the Americans with Disabilities Act of 1990 require an employer to reassign a disabled employee to a position as a reasonable accommodation even though another employee is entitled to hold the position under the employer's seniority system?

No. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the ADA did not require the employer to assign the employee to the mailroom position in violation of the established seniority system. The Court reasoned that an employer's showing that a requested accommodation conflicts with seniority rules is ordinarily sufficient to show that an accommodation is not reasonable. However, the Court added, an employee remains free to present evidence of special circumstances that makes a seniority rule exception reasonable in the particular case. Justice Antonin Scalia, in a dissent joined by Justice Clarence Thomas, argued that the accommodation provision of the ADA requires the suspension, within reason, of employment rules and practices that an employee's disability prevents him from observing. Also dissenting, Justice David H. Souter, joined by Justice Ruth Bader Ginsburg, argued that US Airways failed to establish any burden brought on by accommodating Barnett.