Home From the SSA - Supreme Court Rules on the Relationship Between the Social Security
Act and the Americans with Disabilities Act
In this
discussion:
In keeping with our policy of making available to the public precedential decisions that affect our programs, we published Social Security
Ruling 00-1c: Disability Insurance Benefits--Claims Filed Under Both the Social Security Act and the Americans With Disabilities Act, on
January 7, 2000.
This ruling reprints the text of the Supreme Courts decision in Carolyn C. Cleveland v. Policy Management Systems Corporation, et al.,
decided May 24, 1999, which considered a persons right to seek relief under the ADA if the person has applied for or received Social
Security Disability Insurance (SSDI).
A number of federal courts had held that by applying for or receiving disability benefits, claimants conceded that their impairments were too
severe to permit them to work. The courts held, therefore, that claimants could not at the same time file claims under the ADA in which they
are required to prove that they are capable of working with or without "reasonable accommodation."
The Supreme Court's unanimous decision disagreed and held that there are many situations in which claimants can apply for or receive
SSDI and still exercise their rights under the ADA. The Court further held that, while there may be an appearance of conflict between the
two statutes, and that a Social Security disability claim may turn out to genuinely conflict with an ADA claim, they do not conflict to the
extent that courts should automatically presume that a claimant cannot prove that he or she is capable of "performing the essential
functions" of a job with "reasonable accommodation." The Court believed that there are too many situations in which a Social Security claim
and an ADA claim can comfortably exist side-by-side.
You can find SSR 00-1c at www.ssa.gov/OP_Home/rulings/di/01/SSR00-01-di-01.html.
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From the SSA - Supreme Court Rules on the Relationship Between the Social Security
Act and the Americans with Disabilities Act
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Pub No. 64-040
Issue 1--2000 (No. 25)
Page last updated on June 9, 2000