Sutton v. United Air Lines, Inc.

1999-06-22

Headline: Court limits ADA coverage by ruling that corrected impairments like eyeglasses generally count when deciding disability, letting employers rely on uncorrected vision rules and narrowing who may sue for job discrimination.

Holding: The Court held that the ADA’s disability inquiry must consider corrective measures like eyeglasses, and the applicants who corrected their vision and alleged exclusion from a single pilot job did not state a disability claim.

Real World Impact:

Limits ADA disability finding when impairments are corrected by glasses or contacts.
Permits employers to use uncorrected vision standards for hiring if justified.
Makes it harder to sue claiming disability if you can fully correct your impairment.

Topics: workplace disability, vision requirements, ADA coverage, employer hiring rules

Summary

Background

Two twin sisters with severe nearsightedness applied to be commercial airline pilots. Without glasses their vision was very poor, but with corrective lenses both had 20/20 vision. United Airlines told them they failed the airline’s uncorrected vision requirement, ended their interviews, and did not hire them. The women filed an ADA charge with the EEOC, received a right-to-sue letter, and sued in federal court claiming they were disabled or were regarded as disabled. The district court and the Tenth Circuit dismissed their complaint for failing to state a claim.

Reasoning

The Supreme Court considered whether an individual’s disability must be judged with reference to measures that mitigate the impairment (like eyeglasses) or in a hypothetical uncorrected state. The majority held that disability must be assessed taking account of corrective measures. The Court relied on the statute’s wording, the individualized inquiry the law requires, and the Act’s findings, and it declined to adopt agency guidance that ignored mitigating measures. The Court also addressed the “regarded as” claim and found the sisters alleged only exclusion from a single job (global airline pilot), not exclusion from a broad class of jobs, so that claim failed. The Court affirmed the dismissals.

Real world impact

After this decision, people whose impairments are fully corrected by devices like glasses are less likely to qualify as disabled under the ADA for many job-discrimination claims. Employers may be able to rely on uncorrected physical standards when those standards are legitimately related to the job. The opinion also limits the scope of agency interpretive guidelines that treat people in an uncorrected state.

Dissents or concurrances

Justice Stevens, joined by Justice Breyer, dissented, arguing disability should be judged without regard to mitigating measures and that Congress and agencies intended broader coverage. Justice Breyer added that the EEOC could refine definitions by regulation. Justice Ginsburg concurred with the majority on the narrower reading.