Cleveland v. Policy Management Systems Corporation

PETITIONER: Cleveland
RESPONDENT: Policy Management Systems Corporation
LOCATION: Knowles' Car

DOCKET NO.: 97-1008
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 526 US 795 (1999)
ARGUED: Feb 24, 1999
DECIDED: May 24, 1999

ADVOCATES:
John E. Wall, Jr. - Argued the cause for the petitioner
Matthew D. Roberts - Department of Justice, on behalf of the United States as amicus curiae supporting the petitioner
Stephen G. Morrison - Argued the cause for the respondents

Facts of the case

While working for Policy Management Systems (PMS), Carolyn Cleveland suffered a stroke. Ultimately, she lost her job but was awarded Social Security Disability Insurance (SSDI) benefits because she claimed she was unable to work due to her stroke-induced disability. A week before her SSDI award, Cleveland challenged her termination by PMS as a violation of the 1990 Americans with Disabilities Act (ADA). PMS defended itself by stating that Cleveland's SSDI award negated her ADA suit, because her receipt of SSDI funds proved she was not terminated in spite of an ability to perform her duties. On appeal from adverse rulings in both the lower courts, the Supreme Court granted Cleveland certiorari.

Question

Does application for, and receipt of, Social Security Disability Insurance reflexively bar alleged victims of discrimination from simultaneously pursuing a claim against their former employers under the 1990 Americans with Disabilities Act?

Media for Cleveland v. Policy Management Systems Corporation

Audio Transcription for Oral Argument - February 24, 1999 in Cleveland v. Policy Management Systems Corporation

Audio Transcription for Opinion Announcement - May 24, 1999 in Cleveland v. Policy Management Systems Corporation

William H. Rehnquist:

The opinion of the Court in No.97-1008 will be announced by Justice Breyer.

Stephen G. Breyer:

In 1994, Carolyn Cleveland suffered stroke.

She applied for and then she later received social security disability benefits.

Those are available to disabled people who can't work.

Now, at the same time, her employer discharged her on the ground that she could not any longer adequately perform her job.

She later on brought this lawsuit against her employers.

It's a suit under the Americans with Disabilities Act.

She claims in the suit that she could perform her job with reasonable accommodation.

Now, we granted certiorari in order to consider how to resolve a conflict that might arise when a person tries to assert claims both for social security disability and under the ADA.

The kind of conflict I'm talking about is not purely factual.

As for an example when somebody just says, “Well, the light was red and now it was green.”

Rather the conflict is connected with the statutes, the two statutes, basic legal requirements, an applicant can qualify for SSDI Social Security Disability only if she, “Cannot engage in either her previous work or any other kind of work which exists in the national economy.”

Now, plaintiff can recover under the ADA only if she can perform the essential functions of her job, at least, with reasonable accommodation.

Now, some courts have thought as a result of the requirements I just read that trying to obtain or obtaining relief under both statutes would rather be like saying, “No, I can't work for the SSDI statute”, “No, I can work for the ADA.”

And for that reason, those courts have used the doctrine of judicial estoppel or sometimes they've created presumptions, which make recovery under the ADA difficult or impossible for a person who applied for or received SSDI.

Now, the Fifth Circuit in this case, for example, created a rebuttable presumption that would allow a person who has applied for or received SSDI to recover under the ADA only under what it said, were some limited and highly unusual set of circumstances.

In the opinion that we've written, we -- we disagree with the Fifth Circuit and we hold that courts should not judicially estop an ADA plaintiff or apply a special negative presumption in a case like this one.

That's because there are just too many instances in which the kind of conflict that I just mentioned is only on the surface, but when you go into it more deeply, you discover it isn't real.

Given the administrative needs of the vast governmental SSDI benefits program, for example, the Government cannot easily and does not look into what's called reasonable accommodation when it decides that an applicant can't work for purposes of SSDI.

But a plaintiff could win an ADA suit by showing that she can work only with reasonable accommodation.

Moreover, the Government awards SSDI through applying a matrix.

It's like an administrative matrix that's keyed to systems which in fact means an applicant could qualify for SSDI because the applicant would fall into a certain category, even if that applicant in fact was capable of doing some kinds of work.

And then in certain circumstances, the SSA explicitly awards benefits to those who actually are working in something called a trial-work program, and medical conditions, anyway, can change over time.

Now, for these and related reasons, an SSDI claim and an ADA claim may often exist comfortably side by side.

Still, we do think that an ADA plaintiff cannot simply ignore the fact that she previously applied for or received SSDI.

She must explain how the two claims are compatible and in the context of summary judgment that explanation must warrant a reasonable juror's conclusion that assuming the truth of or the plaintiff's good faith belief in the SSDI claim, she could, nonetheless, perform the essential functions of her job with or without reasonable accommodation.

Carolyn Cleveland believes she can easily provide such an explanation in the trial court.

We therefore vacate the Circuit Court's judgment and remand the case so that she may have an opportunity to do so.

The opinion of the Court is unanimous.