(Case Brief) Sutton v. United Airlines PDF

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Professor Charles Wharton, Case Brief...

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International Disability Rights Law Sutton v. United Airlines Case Brief 1) Facts Two twin sisters, Karen Sutton and Kimberly Hinton, petitioned against United Airlines for discriminatory employment practices on the basis of their eye condition, severe myopia. The sisters argued that such exclusion from the job that they applied for, commercial airline pilots, violated the Americans with Disabilities Act of 1990, which prohibits employers from discriminating qualified individuals with disabilities. With corrective lenses, the sisters improve their vision to 20/20 or better, making them eligible for the job. However, the job required applicants to have a minimum vision requirement of 20/100 or better, so both interviews were terminated and declined a job. 2) Procedural History The EEOC, Attorney General, and Secretary of Transportation have the authority to issue regulations to implement the sections of the ADA, but these agencies have not been delegated the authority to interpret the word “disability”. The Supreme Court affirmed the decision of the Court of Appeals for the Tenth Circuit. 3) Issues/Questions Presented (1) Should the determination of disability under the ADA be made without reference to corrective measures that mitigate the impairment? (2) Is poor vision regarded as an impairment that substantially limits the Suttons in a major life activity? 4) Holdings/Conclusions The court dismissed the sisters’ claims because the sisters’ eyesight condition was not appropriately defined as a “disability” since it could be mitigated with eyeglasses and contact lenses. A disability is defined to be “a physical or mental impairment that substantially limits one or more of the major life activities of such individual”.  Physical or mental impairment: “[a]ny physiological disorder, or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological, musculoskeletal, special sense organs, respiratory (including speech organs), cardiovascular, reproductive, digestive, genito-urinary, hemic and lymphatic, skin, and endocrine.”  Substantially limits: “[u]nable to perform a major life activity that the average person in the general population can perform;” or “[s]ignificantly restricted as to the condition, manner or duration under which an individual can perform a particular major life activity as compared to the condition, manner, or duration under which the average person in the general population can perform that same major life activity.”  Major life activities: functions such as caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working.” The court observed that “[t]he statutory reference to a substantial limitation indicates … that an employer regards an employee as handicapped in his or her ability to work by finding the employee’s impairment to foreclose generally the type of employment involved.”

5) Analysis/Reasoning Overall, the court found that definition of disability should be determined in regards to the individual’s ability to mitigate such impairments. The reason for this is that impairment does not substantially limit a major life activity if it is corrected, and such an interpretation is in line with the agency guidelines. Additionally, with a closer look of Congress’s purpose in passing the ADA, the petitioners’ definition does not apply.  The disability substantially limits… o Because “substantially limits” is worded as such – in present tense – and does not say “would” or “could” substantially limit, the disability is required to be presently limiting rather than potentially limiting o Thus, a disability that is properly corrected does not qualify 6) Your comments Prosthetic limb = considered a disability because it still substantially limits an individual’s ability to run; but what about individuals who have mastered prosthetic limbs and their disability does not substantially limit their life activities because of the advancing technology? How should we consider individuals with disabilities who have options of corrective measures but choose to not do so? Is disability a choice? Dissent  Purpose of the law was to protect individuals with disabilities  We should rather overprotect rather than under-protect  8 of 9 circuit courts, all 3 agencies, and taking into consideration the legislative history and purpose = all considered disability in the state of the unmitigated  Agencies interpreting laws should be considered strong deference (which was not the case for the Sutton case)  2008 ADA Amendments revision  A loss for the interpretation of the ADA  Consideration of the unmitigated state would include too many people (more than Congress had anticipated)...