Clackamas Gastroenterology Assoc., P.C. v. Wells
United States Supreme Court
538 U.S. 440 (2003)
Deborah Wells (plaintiff) worked as a bookkeeper for Clackamas Gastroenterology Associates, P.C. (defendant). After her termination, Wells sued, alleging the clinic violated the Americans with Disabilities Act (ADA), which applies to any employer with at least 15 employees. The clinic had less than 15, unless the four physicians who practiced medicine as the clinic’s shareholders and directors counted as employees. The clinic claimed its doctors were not employees, so the ADA did not apply. The trial court applied an economic realities test used by Seventh Circuit courts to find the doctors more like partners in a partnership than employees and granted the clinic summary judgment. Wells appealed, and the Ninth Circuit reversed, noting that the Second Circuit had rejected the economic realities test. The Supreme Court granted review to resolve the split among the circuits.
Rule of Law
Holding and Reasoning (Stevens, J.)
Dissent (Ginsburg, J.)
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