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

Albertsons Inc. v. Kirkingburg

Before starting his job as a truck driver for Albertsons Inc., Hallie Kirkingburg underwent an eye examination during which he was erroneously certified as meeting basic Department of Transportation (DOT) visual standards. Two years later, in 1992, the error of Kirkingburg's earlier diagnosis was discovered during a routine physical examination. Kinrkingburg was told that he had to obtain a DOT waiver if he wanted to continue driving. Before he could do so, however, Albertsons fired him for failing to meet minimum visual requirements and refused to rehire him even after he obtained the waiver. Kirkingburg challenged his dismissal under the 1990 Americans with Disabilities Act (ADA). On appeal from an adverse Ninth Circuit Court ruling reversing a favorable district court finding, the Supreme Court granted Albertsons certiorari.

Alexander v. Choate

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Barnhart v. Thomas

After a heart attack left her unable to continue working as a housekeeper in the late 1980s, Pauline Thomas took a job as an elevator operator. By the mid-1990s, however, Thomas's job and others like it were eliminated as elevators became automated. Thomas applied for Social Security disability benefits because she could not do other work. The Social Security Administration (SSA), however, rejected her claim because, it said, she was still able to perform the duties of her former position. The fact that it was nearly impossible to find such a position, the SSA held, did not entitle her to benefits under disability law. An administrative judge and a federal district court both upheld the SSA's position, but the Third Circuit Court of Appeals reversed, holding that "a claimant's previous work must be substantial gainful work which exists in the national economy."

Barnhart v. Walton

The Social Security Act authorizes payment of Title II disability insurance benefits and Title XVI Supplemental Security Income to individuals who have an "inability to engage in any substantial gainful activity by reason of any medically determinable...impairment...which has lasted or can be expected to last for a continuous period of not less than 12 months." After developing a serious mental illness, Cleveland Walton lost his job as a teacher in October 1994. Eleven moths later, Walton was working as a cashier. When Walton applied for Title II disability insurance benefits and Title XVI Supplemental Security Income, the Social Security Administration denied him benefits, reasoning that his "inability" to engage in substantial gainful activity lasted only 11 months. The District Court affirmed. In reversing, the Court of Appeals held that the 12-month duration requirement modifies "impairment" not "inability," that no similar duration requirement relates to an "inability," and that, therefore, Walton was entitled to benefits despite regulations restricting them to those unable to work for 12 months. Further, the appellate court concluded that Walton qualified for benefits since, prior to his return to work, his "inability" would have been "expected" to last 12 months.

Bowen v. American Hospital Assn.

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Bowen v. City Of New York

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Bragdon v. Abbott

During a visit to her dentist's office, in order to fill a cavity, Sidney Abbott disclosed that although she did not manifest any obvious symptoms she carried the human immunodeficiency virus (HIV). When her dentist, Randon Bragdon, refused to treat her in his office, offering to conduct any necessary work at a hospital for no extra charge other than use of the facilities, Abbott challenged his policy as discriminatory. After both a federal trial and an appeals court ruled in Abbott's favor, Bragdon appealed and the Supreme Court granted certiorari.

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

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

Garret F., a minor and student in Cedar Rapids Community School District, is wheelchair-bound and ventilator dependent. He requires assistance in attending to his physical needs during the school day. The school district declined to accept financial responsibility for Garret's services in order for him to be able to attend school. The school district believed it was not legally obligated to provide one-on-one care. An Administrative Law judge concluded that the Individuals with Disabilities Education Act (IDEA) required the school district to provide "school health services," which are provided by a "qualified school nurse or other qualified person," but not medical services, which are limited to services provided by a physician. The District Court and the Court of Appeals affirmed despite arguments from the school district that such one-on-one care is too costly and too involved to be considered anything but medical in nature.

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

Beginning in 1972, Mario Echazabal worked for independent contractors at an oil refinery owned by Chevron U.S.A. Inc. When Echazabal applied for a job directly with Chevron, the company's physical examination revealed he had a liver condition, the cause identified as Hepatitis C. Chevron's doctors said that the condition would be exacerbated by continued exposure to toxins at the refinery. In response to Chevron's request that the refinery reassign Echazabal to a job without exposure to toxins or remove him, the contractor employing him laid him off. Echazabal filed suit, claiming that Chevron's action violated the Americans with Disabilities Act of 1990 (ADA). Under an Equal Employment Opportunity Commission (EEOC) regulation that permits the defense that a worker's disability on the job would pose a direct threat to his health, Chevron defended its action. The District Court granted Chevron summary judgment. In reversing, the Court of Appeals found that the regulation exceeded the scope of permissible rulemaking under the ADA.

City of Edmonds v. Oxford House

In Washington State, the City of Edmonds' zoning code provides that the occupants of single-family dwelling units must compose a family, defined as "persons related by genetics, adoption, or marriage, or a group of five or fewer [unrelated] persons." Under the code, Oxford House, which operates a group home for 10-12 adults recovering from alcoholism and drug addiction in a neighborhood zoned for single-family residences, was issued a citation. Oxford House asserted that under the Fair Housing Act (FHA), which prohibits discrimination in housing against persons with handicaps, the city had failed to make reasonable accommodations permitting the maintenance of the group home in a single-family zone. Edmonds sought a declaration that the FHA did not apply to the city's zoning code. The District Court held that the city's zoning code rule defining family was exempt from the FHA under as a reasonable restriction regarding the maximum number of occupants permitted to occupy a dwelling. The Court of Appeals reversed.

Cleveland v. Policy Management Systems

While working for Policy Management Systems (PMS), Carolyn Cleveland suffered a stroke. Ultimately, she lost her job but was awarded Social Security Disability Insurance (SSDI) benefits because she claimed she was unable to work due to her stroke-induced disability. A week before her SSDI award, Cleveland challenged her termination by PMS as a violation of the 1990 Americans with Disabilities Act (ADA). PMS defended itself by stating that Cleveland's SSDI award negated her ADA suit, because her receipt of SSDI funds proved she was not terminated in spite of an ability to perform her duties. On appeal from adverse rulings in both the lower courts, the Supreme Court granted Cleveland certiorari.

Dellmuth v. Muth

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Department Of Transp. v. Paralyzed Veterans

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Florence County School District Four v. Carter

After Shannon Carter was classified as a learning disabled student, school officials met with her parents to formulate an individualized education program (IEP) as required under the Individuals with Disabilities Education Act (IDEA). Unhappy with the IEP developed by the school district, Shannon's parents challenged its appropriateness and enrolled her in a private school while their challenge was pending.

When state and local educational authorities concluded that the IEP was adequate, Shannon's parents sued in Federal District Court, claiming the school district had failed to provide a "free appropriate public education" as required by IDEA and demanding reimbursement for Shannon's education at the private school. The school district argued that the private school did not meet all the requirements of IDEA and therefore did not meet the "appropriate" standard. Because of it was not "appropriate," the school district argued, reimbursement was not required.

The District Court and the Fourth Circuit of Appeals both ruled against the school district, requiring it to reimburse Shannon's parents.

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

At the time of his hiring by United Parcel Service (UPS) to a mechanics position that required him to drive commercial trucks, Vaughn Murphy was misdiagnosed as meeting Department of Transportation (DOT) health guidelines. When UPS discovered that Murphy's blood pressure exceeded DOT requirements, they fired him. Murphy challenged his dismissal as a form of discrimination prohibited under Title I of the 1990 Americans with Disabilities Act (ADA). Following defeat in trial and appellate courts, Murphy appealed and the Supreme Court granted him certiorari.

Olmstead v. Zimring

Jonathan Zimring, on the consolidated behalf of two mentally disabled female patients, challenged Tommy Olmstead, the Commissioner of Georgia's Department of Human Resources, for the Georgia Regional Hospital's (GRH) decision to keep the two women in psychiatric isolation. Zimring argued that under Title II of the 1990 Americans with Disabilities Act (ADA), the women had to be moved to the most communally integrated setting possible. Defending GRH's decision, Olmstead argued that although the women were medically cleared for a more integrated treatment setting, financial constraints and the need to fundamentally alter treatment programs prevented this from happening.

Pennhurst State School v. Halderman

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Pennsylvania Department of Corrections v. Yeskey

After being sentenced to 18 to 36 months in prison, Ronald Yeskey was recommended as a candidate for a Motivational Boot Camp for first-time offenders. Successful completion of the Boot Camp could have resulted in Yeskey's early parole after just six months. When the Pennsylvania Department of Corrections discovered Yeskey's medical history of hypertension, he was denied admission to the Boot Camp. Yeskey challenged the refusal as discriminatory. On appeal from a reversal of a district court's dismissal of the claim, the Supreme Court granted certiorari.

PGA Tour v. Martin

Casey Martin is afflicted with a degenerative circulatory disorder that prevents him from walking golf courses. His disorder constitutes a disability under the Americans with Disabilities Act of 1990 (ADA). When Casey made a request to use a golf cart for the duration of the qualification tournament onto the professional tours sponsored by PGA Tour, Inc., PGA refused. Martin then filed suit under Title III of the ADA, which requires an entity operating "public accommodations" to make "reasonable modifications" in its policies "when... necessary to afford such...accommodations to individuals with disabilities, unless the entity can demonstrate that making such modifications would fundamentally alter the nature of such...accommodations." Ultimately, the District Court entered a permanent injunction against PGA, requiring it to allow Martin to use a cart. The court found that the purpose of the PGA's walking rule was to insert fatigue into the skill of shot-making, and that Martin suffered significant fatigue due to his disability, even with the use of a cart. In affirming, the Court of Appeals concluded that golf courses are places of public accommodation during professional tournaments and that permitting Martin to use a cart would not fundamentally alter the nature of those tournaments.

Pittston Coal Group v. Sebben

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Raytheon v. Hernandez

In 1991, Joel Hernandez tested positive for cocaine use in a drug test administered by his employer. As a result of the incident, he was forced to resign. In 1994, he reapplied for a job from the company. His application was rejected. Hernandez claimed that the company was discriminating against him because of his drug and alcohol addiction (though at the time he reapplied he had been sober for two years) in violation of the Americans with Disabilities Act of 1990. The district court sided with the company, dismissing the case before it ever went to trial. A Ninth Circuit Court of Appeals panel unanimously reversed, however, holding that Raytheon's decision not to rehire Hernandez because of an incident related to his past addiction could constitute discrimination under the act.

Schaffer v. Weast

The parents of Brian Schaffer, a disabled child, sued their public school district under the Individuals with Disabilities Education Act (IDEA). Schaffer's parents claimed the Individualized Education Program that the school system devised for their son, and which IDEA required for each disabled student, was inadequate. The district court ruled for the Schaffers, but the Fourth Circuit reversed, holding that the lower court incorrectly assigned the burden of proof to the school system. Because IDEA was silent on whether the parents or the school system bear the burden of proof, the Fourth Circuit held, the general rule that the party initiating the suit bears that burden should be applied.

Spector v. Norwegian Cruise Line Ltd.

A group of disabled people who travelled on Norwegian Cruise Line ships sued the company in federal district court and alleged two of its ships did not conform with Title III of the Americans with Disabilities Act. The company argued the ADA did not apply to the two ships because, though the ships sailed out of Texas, they sailed under the Bahamian flag. The district court dismissed the group's claims and the Fifth Circuit Court of Appeals ruled foreign-flagged cruise ships are not subject to Title III of the ADA.

Sutton v. United Air Lines

Karen Sutton and Kimberly Hinton (the Suttons) are identical twins who suffer from acute visual myopia. They brought suit against United Airlines (United) under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. Section12101 et seq., after United failed to hire them as commercial airline pilots because their uncorrected vision was worse than 20/100. Although each sister suffered from severe myopia, their vision was correctable with glasses and both sisters were able to function normally in their daily lives. The Suttons claimed that they were disabled within the meaning of the ADA either because, under 42 U.S.C. Section12102(2)(A), they suffered from a physical impairment that "substantially limits . . . major life activities," or because, under 42 U.S.C. Section12102(2)(C), they were regarded as having such an impairment. The district court granted United's 12(b)(6) motion and dismissed the Suttons' complaint for failure to state a claim for which relief could be granted.

Tennessee v. Lane

George Lane and Beverly Jones were disabled and could not access upper floors in Tennessee state courthouses. Lane, Jones, and several others sued Tennessee in federal district court, alleging that by denying them public services based on their disabilities, Tennessee was in violation of Title II of the Americans with Disabilities Act (1990). According to Title II, no person may be denied access to "services, programs, or activities" on the basis of his disability. The act allows alleged victims of discrimination to sue states for damages.

Tennessee asked that the case be dismissed, claiming that it was barred by the 11th Amendment's prohibition of suits against states in federal courts (the sovereign immunity doctrine). The state cited Alabama v. Garrett (2001), in which the U.S. Supreme Court ruled that Congress had acted unconstitutionally in granting citizens the right to sue states for disability discrimination (such as the denial of employment) under the 14th Amendment's equal protection clause. In that case the Supreme Court reasoned that Congress did not have enough evidence of disability discrimination by states to justify the waiver of sovereign immunity.

The district court rejected the state's argument and denied the motion to dismiss. The Sixth Circuit Court of Appeals panel affirmed. The courts reasoned that because Title II of the ADA dealt with the Due process Clause of the 14th Amendment, not the equal protection clause, the ruling in Garrett did not apply. The court found that while Congress may not have had enough evidence of disability discrimination to waive sovereign immunity for equal protection claims, it did have enough evidence of Due Process violations (such as non-handicap-accessible courthouses) to waive the sovereign immunity doctrine for Due Process claims.

Toyota Motor Mfg v. Williams

In 1997, Toyota Motor Manufacturing, Kentucky, Inc. terminated Ella Williams, citing her poor attendance record. Subsequently, claiming to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, Williams sued Toyota for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA). Granting Toyota summary judgment, the District Court held that Williams's impairment did not qualify as a disability under the ADA because it had not substantially limited any major life activity and that there was no evidence that Williams had had a record of a substantially limiting impairment. In reversing, the Court of Appeals found that the impairments substantially limited Williams in the major life activity of performing manual tasks. Because her ailments prevented her from doing the tasks associated with certain types of manual jobs that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time, the appellate court concluded that Williams demonstrated that her manual disability involved a class of manual activities affecting the ability to perform tasks at work.

US Airways v. Barnett

In 1990, Robert Barnett injured his back while working in a cargo-handling position at US Airways. Invoking his seniority rights, Barnett transferred to a less physically demanding position in the mailroom. Subsequently, Barnett's new position became open to seniority-based employee bidding under US Airways' seniority system and, ultimately, he lost his job. Barnett then filed suit under the Americans with Disabilities Act of 1990 (ADA), which prohibits an employer from discriminating against "an individual with a disability" who with "reasonable accommodation" can perform a job's essential functions unless the employer "can demonstrate that the accommodation would impose an undue hardship on the operation of [its] business." In granting US Airways summary judgment, the District Court found that altering a seniority system would result in an "undue hardship" to both US Airways and its nondisabled employees. In reversing, the Court of Appeals held that the seniority system was merely a factor in the undue hardship analysis and that a case-by-case, fact intensive analysis is required to determine whether any particular assignment would constitute an undue hardship.