Sutton v. United Air Lines, Inc.
527 U.S. 471 (1999)

Facts:
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.”

History:
The lower courts dismissed the complaint.

Issue:
Whether disability is to be determined with or without reference to corrective measures.

Holding:
With. Affirmed.

Reasoning:

  • 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.