Labor Law -- 1999



Cleveland v. Policy Management Systems Corp.   (U.S. Supreme Court)

Effect of disability under Social Security Act on ADA claim

The U.S. Supreme Court unanimously ruled that receipt of Social Security Disability Insurance (SSDI) benefits does not automatically estop the recipient from pursuing an ADA claim. The Court further stated that in order to survive a defendant's motion for summary judgment, the plaintiff must explain why her SSDI contention is consistent with her ADA claim that she can "perform the essential functions" of her previous job.

The Fifth Circuit ruled that an employee will find rough sailing in court when she claims she is a "qualified individual with a disability" under the Americans With Disabilities Act (ADA) after she has applied for and received social security disability benefits based on a total disability and inability to work. The court ruled that such a plaintiff must overcome a presumption that her total disability disqualifies her from suing under the ADA. The Supreme Court decided that this presumption is inappropriate.

Many ADA suits are dismissed because plaintiffs make claims under social security and workers' compensation laws, and then try to claim an ability to work under the ADA requirements. Consequently, this case will have a substantial impact on such cases in the future.