Supreme Court Rejects Automatic Bar to ADA Claim for Social Security Applicants

On May 24, 1999, a unanimous U. S. Supreme Court held that a worker who claimed to be "disabled and unable to work" in order to recover Social Security Disability Insurance (SSDI) benefits was not barred from filing a discrimination claim under the Americans with Disabilities Act (ADA). Cleveland v. Policy Management Systems Corporation.

In reversing a decision of the Fifth Circuit Court of Appeals, which had held there was a strong but rebuttable presumption against the claimant's ability to recover under the ADA because of the requirement that the ADA claimant be able to perform the "essential functions" of the job, the Supreme Court emphasized the difference in the statutory schemes involved. According to the Court, pursuit and receipt of SSDI benefits "does not automatically estop the recipient from pursuing an ADA claim," nor "does the law erect a strong presumption against the recipient's success under the ADA."

However, the Court did emphasize that a claimant who alleges inability to work in an SSDI proceeding cannot simply ignore that contention in the ADA case and, in order to survive a defendant's motion for summary judgment, will have to proffer a sufficient explanation why said claim is consistent with the necessary elements of the ADA claim that the essential functions of the job can be performed, at least with reasonable accommodation.