Cleveland v. Policy Management Systems Corp

In Cleveland v. Policy Management Systems Corp. (1999) 526 U.S. 795, the plaintiff had applied for and received Social Security Disability Insurance (SSDI) benefits from the Social Security Administration (SSA). ( Id. at p. 798.) She also sued her former employer alleging that it had terminated her employment without reasonably accommodating her disability in violation of the Americans with Disabilities Act of 1990 (ADA). ( Id. at p. 798-799.) Her former employer moved for summary judgment and the District Court granted the motion "because, in that court's view, [plaintiff,] by applying for and receiving SSDI benefits, had conceded that she was totally disabled" and she was estopped "from proving an essential element of her ADA claim, namely that she could 'perform the essential functions' of her job, at least with 'reasonable accommodation.'" ( Id. at p. 799.) The United States Court of Appeal for the Fifth Circuit affirmed the District Court's grant of summary judgment, but found that the plaintiff's receipt of SSDI benefits created a rebuttable presumption that plaintiff was judicially estopped from claiming that she was a qualified individual with a disability. ( Cleveland, supra, 526 U.S. at p. 800.) The United States Supreme Court analyzed the requirements for receipt of SSDI benefits and concluded that an ADA suit claiming that the plaintiff can perform her job with reasonable accommodation may well prove consistent with the plaintiff's statements to the SSA that she could not perform her own job. ( Id. at p. 804.) The Court explained that "an SSA representation of total disability differs from a purely factual statement in that it often implies a context-related legal conclusion, namely 'I am disabled for purposes of the Social Security Act.'" ( Id. at p. 802.) However, the application for SSDI benefits requires some explanation from the plaintiff. "When faced with a plaintiff's previous sworn statement asserting 'total disability' or the like, the court should require an explanation of any apparent inconsistency with the necessary elements of an ADA claim. To defeat summary judgment, that explanation must be sufficient to warrant a reasonable juror's concluding that, assuming the truth of, or the plaintiff's good faith belief in, the earlier statement, the plaintiff could nonetheless 'perform the essential functions' of her job, with or without 'reasonable accommodation.'" ( Id. at p. 807.)