Cleveland v. Policy Management Systems Corp.
526 U.S. 795, 1999 U.S. LEXIS 3451, 143 L. Ed. 2d 966 (1999)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The pursuit and receipt of Social Security Disability Insurance (SSDI) benefits does not automatically estop a recipient from pursuing a claim under the Americans with Disabilities Act (ADA). To survive a summary judgment motion, the plaintiff must offer a sufficient explanation for the apparent contradiction between the SSDI claim of total disability and the ADA claim of being a 'qualified individual with a disability'.
Facts:
- In August 1993, Carolyn Cleveland began working for Policy Management Systems Corporation.
- On January 7, 1994, Cleveland suffered a stroke that damaged her concentration, memory, and language skills.
- On January 28, 1994, Cleveland filed for SSDI benefits, stating she was 'disabled' and 'unable to work'.
- On April 11, 1994, Cleveland returned to work at Policy Management Systems.
- On July 15, 1994, Policy Management Systems terminated Cleveland's employment.
- On September 14, 1994, Cleveland asked the SSA to reconsider its denial of her benefits, stating she was terminated due to her condition and had not been able to work since.
- Cleveland alleged that before her termination, she requested but was denied reasonable accommodations such as training and additional time to complete her work.
- On September 29, 1995, the SSA awarded Cleveland SSDI benefits, retroactive to the date of her stroke.
Procedural Posture:
- Carolyn Cleveland filed a lawsuit against Policy Management Systems Corporation in U.S. District Court, alleging disability discrimination under the ADA.
- The District Court granted summary judgment for the defendant, Policy Management Systems, concluding that Cleveland was judicially estopped from claiming she was a 'qualified individual' because she had successfully applied for SSDI benefits by stating she was totally disabled.
- Cleveland, the appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit.
- The Fifth Circuit, the intermediate appellate court, affirmed the District Court's decision, holding that the receipt of social security benefits creates a rebuttable presumption that the recipient is judicially estopped from asserting she is a 'qualified individual with a disability.'
- The U.S. Supreme Court granted certiorari to resolve a disagreement among the Circuit Courts on this issue.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the pursuit and receipt of Social Security Disability Insurance (SSDI) benefits automatically estop a plaintiff from pursuing a claim under the Americans with Disabilities Act (ADA) on the grounds that she is a 'qualified individual with a disability'?
Opinions:
Majority - Justice Breyer
No, the pursuit and receipt of SSDI benefits does not automatically estop a recipient from pursuing an ADA claim, nor does it create a strong presumption against the ADA claim's success. The two statutory schemes have different definitions of disability; the Social Security Act does not consider whether an individual could work if provided with a 'reasonable accommodation,' which is a central element of the ADA's definition of a 'qualified individual.' While the two claims do not inherently conflict, an ADA plaintiff cannot ignore her prior sworn statements. She must provide a sufficient explanation for the apparent contradiction to survive summary judgment.
Analysis:
This decision resolves a circuit split and clarifies the relationship between two major federal disability statutes. By rejecting a rule of automatic estoppel or a strong negative presumption, the Court preserves the ability of individuals to seek relief under the ADA even if they have also sought SSDI benefits. The ruling places a procedural burden on the plaintiff to explain the inconsistency, ensuring that courts can still dismiss cases with genuinely conflicting factual assertions. This approach acknowledges the different purposes and standards of the SSDI and ADA systems, preventing the use of SSDI applications as a categorical bar to disability discrimination claims.
