Cleveland v. Policy Management Sys. Corp

119 S. Ct. 1597 (1999). ; Clearinghouse Number: 52255

Description

Claim for Social Security Disability Income Does Not Necessarily Estop Claim Brought Under Americans with Disabilities Act

Abstract

The Supreme Court held that pursuing and then receiving social security disability benefits (SSDI) did not automatically bar the recipient from pursuing a claim under the Americans with Disabilities Act (ADA). After suffering a stroke and losing her job, appellant sought and obtained SSDI benefits. She later filed suit under the ADA and alleged that her former employer discriminated against her because of her disability. The district court concluded that appellant’s claim that she was totally disabled for SSDI purposes estopped her from proving that she could perform the essential functions of her job with accommodation—an essential element of an ADA claim. The Fifth Circuit affirmed, holding that applying for or receiving SSDI benefits creates a rebuttable presumption that an ADA claim is estopped. The appeals court then found that appellant failed to rebut the presumption. Reversing, the Supreme Court held that an SSDI claim and an ADA claim could comfortably exist side by side in many situations. The court reasoned that because "reasonable accommodation" was not an element in determining whether a person was eligible for SSDI, a claim by that same person that she could perform a job with reasonable accommodation was not necessarily inconsistent.

Additional Information

Attorney Information
Petitioner represented by John E. Wall Jr., Law Offices, 5728 Prospect Ave., Dallas, TX 75206; 214.887.0100.
Docket Date
1970-01-01 06:00:00+00:00

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