U.S. Supreme Court Decisions Impacting the ADA

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Page last updated: 7/13/05

The U.S. Supreme Court has interpreted the ADA in the cases listed below. The list contains the name of the case, a brief description of the case and publications related to the case. Cases decided by the Supreme Court during the Court's most recent term are designated with an asterisk (*) in front of the case name. Cases in which the Supreme Court has granted certiorari, but which the court has not yet decided are marked with the word [PENDING] in front of the case name. By clicking on the case name, you will be linked to the case on Westlaw.com. By clicking on [FINDLAW], you will be linked to the case on Findlaw.com, a free internet legal research service.

Albertson's Inc. v. Kirkingburg, 527 U.S. 555, 119 S. Ct. 2162 (1999). [FINDLAW] [WESTLAW]

Held: In judging whether an individual possesses a "disability" within meaning of the ADA, mitigating measures must be taken into account, including both measures undertaken with artificial aids, like medications and devices, and measures undertaken, whether consciously or not, with the body's own systems.

Alexander v. Sandoval, 532 U.S.275, 122 S. Ct. 112 (2001). [FINDLAW] [WESTLAW]

Held: There is no private right of action to enforce the disparate impact regulations promulgated under Title VI of the 1964 Civil Rights Act.

Barnes v. Gorman, ___ U.S. ___, 122 S. Ct. 865 (2002). [FINDLAW] [WESTLAW]

Held: Punitive damages may not be awarded in private suits brought under Title II of the ADA and the Rehabilitation Act.

Bragdon v. Abbott, 524 U.S. 624, 118 S. Ct. 219 (1998). [FINDLAW] [WESTLAW]

Held: From the moment of infection and throughout every stage of the disease, HIV infection satisfies the statutory and regulatory definition of a "physical impairment." The life activity upon which respondent relies, her ability to reproduce and to bear children, constitutes a "major life activity" under the ADA.

Buckhannon Board and Care Home, Inc., et al. v. West Virginia Dept. of Health and Human Resources, et al., 532 U.S. 598, 121 S. Ct. 1835 (2001). [FINDLAW]

Held: The catalyst theory is not a permissible basis for the award of attorneys fees under the FHAA and ADA.

Casey Martin v. PGA, 532 U.S. 661, 121 S. Ct. 1879 (2001). [FINDLAW] [WESTLAW]

Held: A golf course is a place of public accommodation; allowing a golfer to use a cart instead of walking does not fundamentally alter the sport.

Chevron U.S.A., Inc. v. Echazabal, ___ U.S. ___, 122 S.Ct. 2045 (2002). [FINDLAW] [WESTLAW]

Held: Employers can refuse to hire individuals with disabilities who would pose a threat to themselves by performing their jobs.

Cleveland v. Policy Mgmt. Systems Corp., 526 U.S. 795, 119 S.Ct. 1597(1999). [FINDLAW] [WESTLAW]

Held: Pursuit, and receipt, of SSDI benefits does not automatically estop a recipient from pursuing an ADA claim or erect a strong presumption against the recipient's ADA success. However, to survive a summary judgment motion, an ADA plaintiff cannot ignore her SSDI contention that she was too disabled to work, but must explain why that contention is consistent with her ADA claim that she can perform the essential functions of her job, at least with reasonable accommodation.

Edelman v. Lynchburg College, ___ U.S. ___, 122 S. Ct. 1145 (2002). [FINDLAW] [WESTLAW]

Held: Charging parties could verify their charges after the statutory deadline.

EEOC v. Waffle House, Inc., 534 U.S. 279, 122 S. Ct. 754 (2002). [FINDLAW] [WESTLAW]

Held: A private arbitration agreement between an employee and the employer does not prevent the EEOC from suing the employer in its own name and recovering monetary damages for the individual. 

Nevada Dept. of Human Resources v. Hibbs, 538 U.S. 721, 123 S.Ct. 1972 (2003) [FINDLAW] [WESTLAW]

In a 6-3 decision, the Supreme Court decided that state employers could be sued for violating the family care provisions of the Family and Medical Leave Act, known as the FMLA. Nevada Dep’t of Human Resources v. Hibbs, 2003 WL 21210426 (May 27, 2003). The FMLA’s family care provisions require state and local governmental employers, as well as private employers, to provide 12-weeks of unpaid leave to employees for the birth or adoption of a child or for caring for a family member with a serious health condition. Because of the Supreme Court’s decision in Hibbs, state employees can still sue their employers for not providing them with leave to take care of sick parents, spouses and children.

Gonzaga University v. Doe, ___ U.S. ___, 122 S. Ct. 2268 (2002). [FINDLAW] [WESTLAW]

Held: In a decision that has troubling implications for the enforcement of federal rights under Section 1983, the Supreme Court held that a provision of the Federal Educational Rights and Privacy Act (FERPA) is not enforceable under Section 1983.

Murphy v. United Parcel Service, Inc., 527 U.S. 516, 119 S. Ct. 2133 (1999). [FINDLAW] [WESTLAW]

Held: Under the ADA, the determination whether petitioner's impairment "substantially limits" one or more major life activities is made with reference to the mitigating measures he employs.

National Railroad Passenger Corp. v. Morgan, ___U.S. ___, 122 S.Ct. 2061 (2002).[FINDLAW] [WESTLAW]

Held: Employee must file EEOC charge within 300 days of discrete acts of discrimination. Employee may include acts occurring before 300 day period if acts are part of a hostile environment claim and at least one act occurred within the 300 day period.

Olmstead v. L.C., 527 U.S. 581; 119 S.Ct. 2176 (1999) cornell LLI

Pennsylvania Dept of Corrections v. Yeskey, 524 U.S. 206, 118 S. Ct. 1952 (1998). [FINDLAW] [WESTLAW]

Held: Title II of the ADA covers prisons.

Raytheon v. Hernandez, 540 U.S. 44, 124 S.Ct. 513 (2003) [FINDLAW] [WESTLAW]

Held: D isparate treatment and disparate impact claims were cognizable causes of action under the ADA. D isparate treatment means that the employer is motivated to treat some people less favorably than others because of a protected characteristic, e.g., disability. Disparate impact, on the other hand, means that employment practices, which are facially neutral in their treatment of different groups, in fact, fall more harshly on one group than another and can not be justified by business necessity. The Court had been asked to decide whether the ADA confers preferential rights on employees lawfully terminated for misconduct, such an illegal drug use. The Court, however, decided that the Ninth Circuit Court of Appeals had conflated a disparate treatment and disparate impact analysis and remanded the case to the Ninth Circuit to apply a proper disparate treatment analysis.

Sutton v. United Airlines , 527 U.S. 471, 119 S. Ct. 2139 (1999).  [FINDLAW]   [WESTLAW] 

Held:

1. The determination whether an individual is disabled should be made with reference to mitigating measures.

2. Claims that an individual is "regarded as" disabled generally arise when an employer mistakenly believes that an individual has a substantially limiting impairment. An employer's physical criteria are permissible so long as they do not cause the employer to make an employment decision based on an impairment, real or imagined, that it regards as substantially limiting a major life activity.

3. When the major life activity under consideration is that of working, the ADA requires, at least, that one's ability to work be "significantly reduced."

Tennessee v. Lane , ­­­___ U.S. ___, 124 S. Ct. 1978 (2004) [FINDLAW] [WESTLAW]

Held: Title II of the ADA, as applied to cases implicating the fundamental right of access to the courts, constitutes a valid exercise of Congress' enforcement power under the Fourteenth Amendment

Toyota Motor Mfg. v. Williams, 534 U.S. 184, 122 S. Ct. 681 (2002). [FINDLAW] [WESTLAW]

Held: The Court unanimously held that to be considered substantially limited with respect to manual tasks, an individual must have a manual impairment that "prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives."

University of Alabama v. Garrett, 531 U.S. 356, 121 S.Ct. 955 (2001). [FINDLAW] [WESTLAW]

Held: The ADA does not abrogate state sovereign immunity.

U.S. Airways, Inc. v. Barnett, Inc., ___ U.S. ___, 122 S. Ct. 1516 (2002). [FINDLAW] [WESTLAW]

Held: An accommodation is "ordinarily" not reasonable when there is a conflict between a requested accommodation and a seniority system, regardless of whether the system is included in a collective bargaining agreement. But, an accommodation may be reasonable if an employee can show "special circumstances," e.g. a seniority system so riddled with exceptions that one more exception (the requested accommodation) would not matter.