Tuesday, October 8, 2013

Sutton v. United Air Lines Case Brief Summary

Sutton v. United Air Lines 
Employment Law

Recommended Outlines for Employment and Labor Law:
Employment Law in a Nutshell
Gilbert Law Summaries: Labor Law

FACTS:
-Twin sisters, each suffered from severe myopia, which was correctable with appropriate lenses.
-They both applied for positions as pilots with the airline (D).
-The applicants contended that the airline's refusal to hire them as pilots because of their uncorrected visual acuity was based upon their disability and was impermissible discrimination under the ADA.

PROCEDURAL HISTORY:
-The district court dismissed the applicants' complaint for failure to state a claim upon which relief could be granted, and the appeals court affirmed the decision. 
-The Court affirmed the decision below because a "disability" under the ADA had to be determined with regard to the corrective measures that were available and a person whose physical or mental impairment was corrected by medication or other measures did not have an impairment that substantially limited a major life activity.

OUTCOME:
-The Court affirmed the decision upholding the trial court's dismissal of the applicants' claims under the Americans with Disabilities Act because the applicants were not disabled within the meaning of the statute.

ISSUE :  
-Is myopia or bad eyesight a disability?

RULES:  
-EEOC regulations define 3 elements of disability – (1) physical or mental impairment; (2) substantially limits; (3) MLA

HOLDING:
This case holds that corrective measures must be taken into account when defining disability

ANALYSIS:
-If the condition can be cured by corrective measures, this must be taken into account in deciding whether the impairment “substantially limits” a MLA.
-ER can discriminate based on physical or medical characteristics that do not rise to the level of disability as well as decide that some limiting, but not substantially limiting impairments make EEs less suitable.

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