Cleveland v. Policy Mgmt. Sys. Corp. - 526 U.S. 795, 119 S. Ct. 1597 (1999)

Rule:

Pursuit and receipt of Social Security Disability Insurance (SSDI) benefits under 42 U.S.C.S. § 423(d)(2)(A) does not automatically estop the recipient from pursuing a claim under the Americans with Disabilities Act of 1990 (ADA), seeking reasonable accommodation pursuant to 42 U.S.C.S. § 12111(8). Nor does the law erect a strong presumption against the recipient's success under the ADA. Nonetheless, an ADA plaintiff cannot simply ignore her SSDI contention that she was too disabled to work. To survive a defendant's motion for summary judgment, she must explain why that SSDI contention is consistent with her ADA claim that she could "perform the essential functions" of her previous job, at least with "reasonable accommodation." 

Facts:

After suffering a stroke and losing her job, petitioner Cleveland sought and obtained Social Security Disability Insurance (SSDI) benefits, claiming that she was unable to work due to her disability. The week before her SSDI award, she filed suit under the Americans with Disabilities Act of 1990 (ADA), contending that her former employer, respondent Policy Management Systems Corporation, had discriminated against her on account of her disability. In granting Policy Management Systems summary judgment, the District Court concluded that Cleveland's claim that she was totally disabled for SSDI purposes estopped her from proving an essential element of her ADA claim, namely, that she could "perform the essential functions" of her job, at least with "reasonable . . . accommodation," 42 U.S.C. § 12111(8). The Fifth Circuit affirmed, holding that the application for or receipt of SSDI benefits creates a rebuttable presumption that a recipient is estopped from pursuing an ADA claim and that Cleveland failed to rebut the presumption.

Issue:

Did the pursuit and receipt of SSDI benefits estop employment discrimination claim under ADA?

Answer:

No.

Conclusion:

The Supreme Court vacated and remanded because receipt of SSDI benefits did not automatically bar Cleveland from maintaining an ADA action. Improvement in a plaintiff's condition might allow her to return to work with reasonable accommodation. Where plaintiff offered sufficient explanation of the inconsistency in her statements, summary judgment for defendant was inappropriate.