Cleveland v. Policy Management Systems Corp.

Summary

The unanimous Court held that applying for or receiving Social Security Disability Insurance benefits neither automatically estops a claimant from pursuing an ADA employment-discrimination claim nor creates a special presumption against that claim. The statutes can coexist because SSDI determinations do not consider reasonable accommodation and may reflect administrative presumptions or circumstances different from those relevant to the ADA claim. Nevertheless, to survive summary judgment, a plaintiff must sufficiently explain an apparent inconsistency between a prior assertion of total disability and her claim that she could perform her job’s essential functions with or without reasonable accommodation. The Court vacated the Fifth Circuit’s judgment and remanded to permit the parties to present or contest Cleveland’s explanations. There were no separate opinions.