Sutton v. United Air Lines, Inc.

Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999), was a case decided by the Supreme Court of the United States on June 22, 1999. The Court decided that mitigating measures should be taken into account when determining whether one's impairment constitutes a disability under the Americans with Disabilities Act of 1990 (ADA). The holding of this case was later overturned by the passage of the ADA Amendments Act of 2008.[1][2]

Sutton v. United Air Lines, Inc.
Argued April 28, 1999
Decided June 22, 1999
Full case nameKaren Sutton and Kimberly Hinton, Petitioners v. United Air Lines, Inc.
Docket no.97-1943
Citations527 U.S. 471 (more)
ArgumentOral argument
Case history
SubsequentOverturned by Americans with Disabilities Act Amendments Act of 2008
Holding
Mitigating measures should be taken into consideration when determining whether an impairment constitutes a disability under the ADA.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityJustice O'Connor
ConcurrenceJustice Ginsburg
DissentJustice Stevens, joined by Justice Breyer
Laws applied
Americans with Disabilities Act of 1990
Superseded by
ADA Amendments Act of 2008

Background

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Twins Karen Sutton and Kimberly Hinton suffered from severe myopia. Their uncorrected visual acuity was 20/200, but with corrective lenses, both were able to function normally. They applied to United Air Lines to be commercial airline pilots, but were rejected by the company due to their uncorrected vision being worse than 20/100. The twins then filed suit under the Americans with Disabilities Act of 1990 in the U.S. District Court for the District of Colorado. The District Court dismissed the complaint, partially holding that the plaintiffs could not be considered “disabled” because their impairment could be fully corrected. The United States Court of Appeals for the Tenth Circuit affirmed. The plaintiffs then appealed to the Supreme Court.[3][4][5] The American Civil Liberties Union also filed an amicus brief in support of the plaintiffs.[6]

Decision

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In a 7–2 decision delivered by Justice O’Connor, the U.S. Supreme Court affirmed, holding that “the determination of whether an individual is disabled should be made with reference to measures that mitigate the individual's impairment, including, in this instance, eyeglasses and contact lenses.”[7]

Significance

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Prior to the Sutton decision, courts were divided on whether ameliorative effects of mitigating measures should be taken into consideration when determining whether an impairment is a disability. Sutton's interpretation of the ADA ended this disagreement.[8]

Subsequent history

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The ADA Amendments Act was passed in 2008 in response to controversial Supreme Court decisions, including Sutton and Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, that narrowed the definition of disability under the ADA.[2][9] According to the "Findings and Purposes" section of the ADAAA, "the holdings of the Supreme Court in Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999) and its companion cases have narrowed the broad scope of protection intended to be afforded by the ADA, thus eliminating protection for many individuals whom Congress intended to protect."[9]

See also

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References

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  1. ^ Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999)
  2. ^ a b "Questions and Answers about the Department of Justice's Notice of Proposed Rulemaking to Implement the Americans with Disabilities Act Amendments Act of 2008". archive.ada.gov. Retrieved September 7, 2023.
  3. ^ "Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999)". Justia Law. Retrieved September 7, 2023.
  4. ^ "Sutton v. United Air Lines, Inc." Oyez, www.oyez.org/cases/1998/97-1943. Accessed 6 Sep. 2023.
  5. ^ Hall, Julia J. (2000). "Sutton v. United Air Lines, Inc.: The Role of Mitigating Measures in Determining Disabilities". Mercer Law Review.
  6. ^ "Sutton v. United Air Lines, Inc". American Civil Liberties Union. Retrieved March 11, 2024.
  7. ^ 527 U.S. at 475.
  8. ^ Harrington, Christine M. (2000). "The Americans with Disabilities Act: The New Definition of Disability Post: Sutton v. United Air Lines, Inc.". Marquette Law Review.
  9. ^ a b "ADA AMENDMENTS ACT OF 2008". US EEOC. Retrieved September 7, 2023.
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