Sutton v. United Air Lines, Inc.
527 U.S. 471 (1999)
Petitioners were twin sisters, both of whom had severe myopia. With contacts, however, their vision was 20/20 or better. They applied to be commercial airline pilots but were rejected because they did not meet minimum vision requirement.
- Consequently, they filed suit under the Americans with Disabilities Act of 1990 (ADA), which prohibits covered employers from discriminating against individuals on the basis of their disabilities.
- Among other things, the ADA defines a “disability” as “a physical or mental impairment that substantially limits one or more of the major life activities.”
The lower courts dismissed the complaint.
Whether disability is to be determined with or without reference to corrective measures.
- A person can’t be “substantially limited” for “disability” purposes when the corrective measures they use effectively remove any impairments.
- Furthermore, Congress’ estimated at the time of ADA’s enactment that 43 million Americans had disabilities.
- This showed its intent to not include those with uncorrected conditions, because it would’ve cited a much higher number.
Rule: Corrective and mitigating measures should be considered in determining whether individual is disabled under ADA.
Important Note: ADA Amendments Act of 2008:
- “The determination of whether an impairment substantially limits a major life activity shall be made without regard to the ameliorative effects of mitigating measures such as medication, medical supplies, equipment;…use of assistive technology; reasonable accommodations or auxiliary aids or services; or learned behavioral or adaptive neurological modifications.”
- “The ameliorative effects of the mitigating measures of ordinary eyeglasses or contact lenses shall be considered in determining whether an impairment substantially limits a major life activity.”
Thus, the result here would’ve been the same under the new provisions, but the doctrine established by the case has been expressly overruled.