U.S. Airways, Inc. v. Barnett

No. 00-1250 (U.S. Apr. 29, 2002), No. 96-16669 (9th Cir. Oct. 4,; Clearinghouse Number: 53202

Description

Proposed Accommodation of Employee's Disability Is Normally Rendered Unreasonable If the Accommodation Would Violate a Seniority System's Rules

Abstract

The Supreme Court has held that an employer's showing that a requested accommodation conflicts with seniority rules is ordinarily sufficient to show, as a matter of law, that an accommodation is not reasonable. After respondent employee suffered an injury on the job, petitioner employer transferred him to a less physically demanding mailroom position. Employee's new position later became open to seniority-based employee bidding under employer's seniority system, and employees senior to respondent planned to bid on the job. Employer refused respondent's request to accommodate his disability by allowing him to remain in the mailroom, and he lost his job. Respondent claimed that employer had discriminated against him in violation of the Americans with Disabilities Act, 42 U.S.C. ยง 12112. Finding that altering a seniority system would result in an "undue hardship" to both employer and its nondisabled employees, the district court granted employer's motion for summary judgment. Reversing, the Ninth Circuit held that the seniority system was merely a factor to be considered 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. Vacating and remanding, the Supreme Court held that the statute does not require proof on a case-by-case basis that a seniority system should prevail because it would not be reasonable in the run of cases that the assignment trump such a system's rules. The Court noted that a typical seniority system provides important employee benefits by creating, and fulfilling, employee expectations of fair, uniform treatment that might be undermined if an employer were required to show more than the system's existence. The Court held that respondent remains free to show that special circumstances warrant a finding that, despite the seniority aystem's presence, the requested accommodation is reasonable on the particular facts. The Court noted that special circumstances might alter the important expectations created by a seniority system, for example, if the system already contains exceptions such that, in the circumstances, one further exception is unlikely to matter.

Additional Information

Attorney Information
Docket Date
2002-04-29 05:00:00+00:00