The Social Security Act (SSA) provides disability insurance (SSDI) for individuals with a disability that, considered in the light of their age, training, and experience, makes it impossible for them to work in the U.S. economy. The Americans with Disabilities Act (ADA) prevents employers from discriminating against employees with a disability that are otherwise qualified to do a job and can do it with a reasonable accomodation. This case arises from a seeming conflict between these laws: Can a plaintiff who claims she is totally disabled in an application for SSDI also claim that she is otherwise qualified and employable if she is given a reasonable accomodation? The Fifth Circuit ruled that such a plaintiff was estopped from claiming under the ADA, but other circuits had reached differing results, so the United States Supreme Court reviewed the Fifth Circuit case to resolve the split among the circuits.

Plaintiff had worked for some time for her employer. She had a stroke, which impaired her concentration and ability to remember. At first, she was unable to return to work and filed a claim for SSDI. Later, she improved and returned to work. She notified the Social Security Administration (SSA) of her return to work and they denied her benefits because she was able to work. A few days later, she was fired for not being able to perform the job. She amended her applications for SSDI and was eventually granted benefits. At the same time, she sued her employer under the ADA for not providing reasonable accomodation to allow her to return to work. The trial judge dismissed her compliant on the pleadings, finding that her representation to the SSA that she was totally disabled prevented her from prosecuting a claim for compensation under the ADA because she was not otherwise qualified to perform the job. She was not given a chance to address the factual issues and demonstrate whether her two claims were identical, or whether they could be distinguished. The Fifth Circuit affirmed the trial court's decision.

The United States Supreme Court looked carefully at the underlying statutes and focused on one key difference: The SSDI provisions deal with the person's condition without accomodation, and the ADA is based on providing reasonable accomodation for the disability. SSDI determinations are classic "grid" regulations, in that there are a set of standards for qualifications and the claimant qualifies if she meets the right combination of them. They do not require a detailed analysis of the claimant's specific work skills or history, as would be required for a reasonable accomodation analysis. In some circumstances, the claimant may even be able to work and still satisfy the requirements as long as she does not take a job. (The qualifying conditions have been partially shaped by direct Congressional action and reflect political, rather than medical, determinations.) The ADA, by contrast, depends on individualized factual inquiry. The disabled individual may propose a way to do her job that will accommodate her disability. Without such an accomodation, she cannot work and is totally disabled under the SSDI criteria. The employer must provide the accomodation if it is reasonable, which is based on the cost of the accomodation and whether it requires that the job be so modified that employee is no longer doing an essential function of the job. If the employer provides the accomodation and the claimant takes the job, that will eventually end the SSDI. (There are provisions to continue benefits for a trial of work.) Until an employer provides such a job, the claimant is disabled under the terms of the SSDI regulations.

The Court recognized that in many circumstances the claim for SSDI will conflict with the claim for ADA compensation. In these cases the plaintiff must explain, to the jury's satisfaction, how to reconcile the two claims or she will lose her ADA claim. If she is unable to make such a showing in her pleadings, it may be appropriate for the court to dismiss the case. The court may not assume, however, that the mere existence of a claim for SSDI will preclude a successful ADA claim.