2002 Cases

Arbitration of Employment Disputes

M. Equal Employment Opportunity Commission v. Waffle House, Inc., 122 S.Ct. 754 (2002)

The Court reasoned that the EECO's statutory enforcement powers unambiguously authorized the EEOC to obtain the relief that it sought in its complaint, if it could prove its case against the employer. The Court further noted that no language existed to suggest that an arbitration agreement between private parties materially changed the EEOC's statutory function or the remedies otherwise available.

Definition of Disability

Toyota Motor Manufacturing, Kentucky Inc. v. Williams (2002)

The Court holds that a person is substantially limited in a major life activity, within the meaning of the ADA, if he or she has 'an impairment that prevents or significantly restricts the individual from doing activities that are of central importance to most people's daily lives.'

Direct Threat

O. Chevron U.S.A. Inc. v. Echazabal, 122 S.Ct. 2045 (2002)

The Court held that the ADA did not preclude the EEOC's regulation allowing the harm-to-self-defense. The Court reasoned that deference applied to the regulation because it made sense of the statutory defense for qualification standards that are job-related and consistent with business necessity. The Court also found that the risk of violating the Occupational Safety and Health Act of 1970 (OSHA) was enough to show that the regulation was permissible.

Punitive and Compensatory Damages

P. Barnes v. Gorman, 122 S.Ct. 2097 (2002)

The Court held that, because punitive damages may not be awarded in private suits brought under Title VI of the 1964 Civil Rights Act, it follows that they may not be awarded in suits brought under the ADA and the Rehabilitation Act. The Court noted that the remedies of the sections of the ADA and the Rehabilitation Act Gorman sued under are coextensive with those available in a private action under Title VI. Under a contract-law analogy, the Court reasoned because Title VI- funding recipients did not, merely by accepting funds, implicitly consent to liability for punitive damages, it followed that they could not be awarded in suits brought under the ADA and the Rehabilitation Act.

Reasonable Accommodation

N. U.S. Airways, Inc. v. Barnett, 122 S.Ct. 1516 (2002)

The Court held that the ADA did not require the employer to assign the employee to the mailroom position in violation of the established seniority system. The Court reasoned that an employer's showing that a requested accommodation conflicts with seniority rules is ordinarily sufficient to show that an accommodation is not reasonable. However, the Court added, an employee remains free to present evidence of special circumstances that makes a seniority rule exception reasonable in the particular case.