Sutton v. United Airlines, Inc.
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| Sutton v. United Airlines, Inc. | |
|---|---|
| Name | Sutton v. United Airlines, Inc. |
| Court | Supreme Court of the United States |
| Decided | 1999 |
| Citations | 527 U.S. 471 |
| Docket | 98-101 |
| Judges | William Rehnquist, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer |
| Majority | O'Connor |
| Laws | Americans with Disabilities Act of 1990 |
Sutton v. United Airlines, Inc. was a 1999 decision of the Supreme Court of the United States interpreting the Americans with Disabilities Act of 1990 as applied to employees with mitigated impairments. The Court held that when determining whether an individual's impairment substantially limits a major life activity, courts must consider measures that mitigate the impairment. The ruling shaped ADA case law and provoked legislative and judicial responses across subsequent disputes involving disability rights, workplace discrimination, and civil rights enforcement.
Background
The dispute arose against the backdrop of the enactment and enforcement of the Americans with Disabilities Act of 1990, landmark civil rights legislation advocated by figures associated with disability advocacy and shaped in part by debates in the United States Congress, including the House Judiciary Committee and the Senate Judiciary Committee. The ADA followed earlier federal statutes such as the Rehabilitation Act of 1973 and engaged actors like the Equal Employment Opportunity Commission, legal scholars at institutions like Harvard Law School and Yale Law School, and advocacy groups including American Association of People with Disabilities, National Council on Independent Living, and American Civil Liberties Union. Litigation over ADA coverage involved courts from district courts to the United States Court of Appeals for the Eighth Circuit before reaching the Supreme Court under Chief Justice William Rehnquist.
Facts of the Case
Two sisters, Karen Sutton and Kimberly Hinton, applied for positions as plane mechanics with United Airlines, Inc., a major carrier headquartered in Chicago. Sutton and Hinton each had severe myopia corrected by eyeglasses to visual acuities within United's hiring standards; both had prior cataract surgery and relied on corrective lenses. United enforced a visual acuity requirement stemming from Federal Aviation Administration standards and company safety policies developed by corporate counsel and personnel managers. After United denied their applications, Sutton and Hinton filed charges with the Equal Employment Opportunity Commission and initiated suits under the ADA in federal district court in Missouri, alleging that United discriminated in violation of the ADA and remedies under the Civil Rights Act of 1964 framework.
Legal Issues and Proceedings
The primary legal question concerned the statutory definition of "disability" under the ADA, specifically whether an individual's impairment must be judged in its unmitigated state or while considering mitigating measures such as eyeglasses or medication. Lower courts examined precedent from the Rehabilitation Act of 1973 and compared interpretations in circuits including the Eighth Circuit Court of Appeals and the Seventh Circuit Court of Appeals. Briefing and oral argument involved counsel citing authorities like Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. on statutory interpretation, constitutional principles discussed in Marbury v. Madison, and ADA enforcement positions articulated by the Equal Employment Opportunity Commission. Amicus briefs from disability organizations such as National Federation of the Blind, labor entities like the AFL–CIO, and civil liberties groups influenced the record presented to the Court.
Supreme Court Decision
In a majority opinion authored by Justice Sandra Day O'Connor, the Court held that the term "substantially limits" in the ADA must take into account corrective measures that mitigate impairments, such as eyeglasses or medication, consistent with textualist and purposive statutory analysis. The decision reversed the Eighth Circuit and concluded that Sutton and Hinton were not "disabled" under the ADA because their corrected vision met United's standards. The majority engaged with precedents including School Board of Nassau County v. Arline and discussed statutory constructions that echoed reasoning from cases like United States v. Georgia and Olmstead v. L.C.. Dissenting and concurring opinions by Justices John Paul Stevens, Ruth Bader Ginsburg, and Stephen Breyer emphasized broader interpretations aligned with legislative intent expressed by members of Congress such as Representative Tony Coelho and Senator Tom Harkin.
Impact and Legal Significance
The Sutton ruling narrowed the class of individuals covered as disabled under the ADA by endorsing a mitigation-based assessment, affecting employment discrimination litigation involving conditions treated by devices or medications. The decision influenced enforcement by the Equal Employment Opportunity Commission and prompted analysis by scholars at Columbia Law School, Stanford Law School, and New York University School of Law. Employers including Delta Air Lines, American Airlines, and Southwest Airlines reviewed hiring policies, while civil rights litigants adjusted strategies in cases concerning accommodations under statutes like the Air Carrier Access Act and claims before bodies such as the Department of Justice and federal district courts in California and New York. The ruling also animated legislative responses and advocacy campaigns by groups such as ADA Watch and Disability Rights Education and Defense Fund.
Subsequent Developments and Related Jurisprudence
Congress responded by enacting amendments, notably the ADA Amendments Act of 2008, which legislatively overruled aspects of Sutton by broadening the definition of disability and directing courts to construe the ADA generously. Post-amendment cases in circuits like the Second Circuit Court of Appeals, Ninth Circuit Court of Appeals, and Federal Circuit re-evaluated mitigation questions in light of statutory change. The Supreme Court later addressed related issues in decisions such as Toyota Motor Manufacturing, Kentucky, Inc. v. Williams and considered ADA scope in contexts involving public entities under Title II of the ADA and private employers under Title I of the ADA. Academic commentary in journals like the Harvard Law Review, Yale Law Journal, and University of Chicago Law Review continues to assess Sutton's doctrinal legacy, and disability advocates persist in litigating accommodations before tribunals including the Office of Federal Contract Compliance Programs and state human rights commissions.