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Alexander v. Washington Metropolitan Area Transit Authority

Court of Appeals for the D.C. Circuit
826 F.3d 544, 423 U.S. App. D.C. 380 (2016)
ELI5:

Rule of Law:

Under the Rehabilitation Act, which incorporates the ADA's definitions, an individual can establish they have a "disability" by meeting any one of three prongs: (1) an actual impairment that substantially limits a major life activity, (2) a record of such an impairment, or (3) being regarded as having such an impairment. Under the "regarded as" prong, a plaintiff need only show that an employer took a prohibited action because of an actual or perceived impairment, not that the impairment substantially limited a major life activity.


Facts:

  • Carlos Alexander has suffered from alcoholism since approximately 1980.
  • The Washington Metropolitan Area Transit Authority ('Authority') hired Alexander in 1999.
  • In 2007, Alexander tested positive for alcohol at work and was suspended.
  • In January 2009, Alexander again tested positive for alcohol while at work and was terminated from his employment.
  • During his exit interview, the Authority informed Alexander that he could apply for rehire in one year if he successfully completed an intensive alcohol dependency treatment program.
  • Alexander completed such a program in January 2010.
  • Between April 2010 and October 2011, Alexander applied for re-employment with the Authority three times but was rejected on each occasion.
  • During the re-application process, Authority representatives allegedly gave shifting reasons for the rejections, including statements that he could not return because he had failed the program that led to his termination and that rehiring him would 'open the floodgates for people like [him].'

Procedural Posture:

  • Carlos Alexander filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC) on September 13, 2010.
  • The EEOC found reasonable cause to believe the Authority had violated the Americans with Disabilities Act (ADA) and issued Alexander a 'right to sue' letter on September 7, 2012.
  • Alexander filed a complaint in the U.S. District Court for the District of Columbia, alleging violations of the Rehabilitation Act and the ADA.
  • Alexander voluntarily dismissed his ADA claim.
  • The Authority moved for summary judgment.
  • The district court granted the Authority’s motion for summary judgment, holding that Alexander failed to establish he was an individual with a disability.
  • Alexander, as appellant, appealed the district court's judgment to the U.S. Court of Appeals for the D.C. Circuit.

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Issue:

Did the district court err in granting summary judgment to an employer on a disability discrimination claim by finding the plaintiff was not 'disabled' under the Rehabilitation Act, where the court only analyzed the 'actual disability' prong and failed to consider the 'record of' and 'regarded as' prongs of the statutory definition?


Opinions:

Majority - Per Curiam

Yes. The district court erred in granting summary judgment because it failed to properly consider the record evidence as it applied to all three of the Rehabilitation Act’s alternative definitions of 'disability.' The court's analysis focused only on the first prong—whether Alexander had an actual impairment that substantially limited a major life activity—and completely ignored the 'record of' and 'regarded as' prongs, even though Alexander had alleged discrimination on those grounds. The 2008 ADA Amendments Act significantly broadened the 'regarded as' prong, making it a primary path for such claims. Under the amended law, a plaintiff asserting a 'regarded as' claim no longer needs to show that the employer perceived the impairment as substantially limiting a major life activity; they must only demonstrate that the employer took a prohibited action against them because of an actual or perceived impairment. Alexander presented sufficient evidence for a jury to conclude the Authority refused to rehire him because of his alcoholism, which is an undisputed impairment.



Analysis:

This decision underscores the significant impact of the ADA Amendments Act of 2008, which was designed to broaden the scope of protection under federal disability law. The court's reversal clarifies that lower courts must analyze all three prongs of the 'disability' definition when raised by a plaintiff. By emphasizing the relaxed standard for 'regarded as' claims, the ruling makes it easier for plaintiffs to survive summary judgment, shifting the focus from the severity of their impairment to the employer's motive for the adverse action. This strengthens protections against discrimination based on stereotypes or perceptions of impairment, regardless of an individual's actual functional limitations.

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