Sutton v. United Airlines (1999)
- Sam Shepherd
- Sep 16, 2024
- 3 min read
Updated: Oct 27, 2024
By Andrew Dawson
Overview
In Sutton v. United Air Lines, Inc., the U.S. Supreme Court ruled that mitigating measures should be accounted for when determining whether an individual has a disability under the Americans with Disabilities Act of 1990 (ADA). However, this ruling was overturned by the passage of the ADA Amendments Act of 2008.
Summary
Karen Sutton and Kimberly Hinton (the plaintiffs) are twins, both of whom suffered from visual myopia, resulting in their uncorrected vision to be 20/200. However, corrective eyeglasses were able to mitigate this, allowing the sisters to have 20/20 vision. The sisters applied to be global airline pilots for United Air Lines (the defendant), but were disqualified during their interviews as a result of their uncorrected vision being below the 20/100 threshold.
The sisters sued United, citing that the defendant violated the ADA by discriminating against them due to their disability. The plaintiffs argued that their uncorrected myopia was a “substantially limiting impairment,” and thus they were protected under the ADA. The U.S. District Court for the District of Colorado dismissed the complaint, citing the plaintiffs failed to state a claim where relief could be granted. Further, the District Court determined the sisters “were not actually disabled” because through corrective measures, the twins were “able to function identically to individuals without a similar impairment,” and thus, their fully corrected vision “did not substantially limit a major life activity” (Sutton v. United Air Lines, Inc. (1997)).
The sisters appealed to the United States Court of Appeals for the Tenth Circuit, claiming the District Court incorrectly dismissed their claim to be protected under the ADA and erred in evaluating their claim under the Equal Employment Opportunity Commission’s (EEOC) Guidance, which states determination of a disability under the ADA must be done without regarding mitigating or corrective measures. The Appeals Court affirmed the District Court’s decision. The Appeals Court argued the plaintiffs had presented a case where they were unable to satisfy the requirements of a particular job, global airline pilot, but had not presented a claim where a disability was substantially limiting towards major life activities of working, and thus were not protected under the ADA (Sutton v. United Air Lines, Inc. (1997)).
The Supreme Court granted certiorari (judicial review of lower court decisions), pointing to numerous precedents “in tension” with the Tenth Circuit’s decision. In a 7-2 decision, the Supreme Court affirmed the lower courts decisions. Justice O’Connor authored the majority opinion, citing that the determination of a disability under the ADA should be made in reference with the measures that can mitigate the individual’s impairment. Further, the Court found that the Sutton’s were not protected under the ADA because their vision was not a “substantially limiting impairment” (Sutton v. United Air Lines, Inc. (1999)). The Court argued that this can preclude the sisters from being global airline pilots, but does not from numerous other positions, including in the aviation industry (Sutton v. United Air Lines, Inc., Oyez).
Justices Breyer and Stevens dissented, arguing they were persuaded that the Sutton’s have a disability covered by the ADA. Further In Justice Stevens dissent, he argued that the case should be decided without considering if/how mitigating measures impact in determining whether an individual is substantially limited in a major life activity (Hall, 2000).
Impact
There were two key impacts from the Sutton decision. First, there was some ambiguity between courts whether to include or exclude the impacts of mitigating measures in determining whether an impairment qualifies as a disability under the ADA. The Sutton decision clarified this disagreement (Hall, 2000). Second, in 2008, the ADA Amendments Act (ADAAA) was passed to broaden the scope of what disabilities limit a “major life activity” are protected, including functions such as walking and communicating and bodily functions, thus eliminating the Sutton ruling and precedent (Britannica and EEOC, 2008).
Court Documents
Americans with Disabilities Act of 1990 including the changes made by the ADA Amendments Act of 2008
Citations
“Americans with Disabilities Act.” Encyclopædia Britannica, Encyclopædia Britannica, inc., 27 Aug. 2024, www.britannica.com/topic/Americans-with-Disabilities-Act#ref1071331.
Hall, Julia J. Sutton v. United Air Lines, Inc.: The Role of Mitigating Measures in Determining Disabilities , Mercer Law Review, Mar. 2000, digitalcommons.law.mercer.edu/cgi/viewcontent.cgi?article=1273&context=jour_mlr.
“Notice Concerning The Americans With Disabilities Act (ADA) Amendments Act of 2008.” US Equal Employment Opportunity Commission (EEOC), www.eeoc.gov/statutes/notice-concerning-americans-disabilities-act-ada-amendments-act-2008. Accessed 10 Sept. 2024.
Sutton v. United Air Lines, Inc. (1997) Tenth Circuit of Appeals, casetext.com/case/sutton-v-united-air-lines-inc. Accessed 10 Sept. 2024.
“Sutton v. United Air Lines, Inc., (1999) Supreme Court.” Justia Law, supreme.justia.com/cases/federal/us/527/471/. Accessed 10 Sept. 2024.
"Sutton v. United Air Lines, Inc." Oyez, www.oyez.org/cases/1998/97-1943. Accessed 10 Sep. 2024.
