Cleveland v. Policy Management Systems Corp.

Carolyn Cleveland (plaintiff) was awarded Social Security disability insurance (SSDI) benefits after she had a stroke and lost her job. Before she was fired, Cleveland asked her employer to accommodate her disability by providing her with additional training or with extra time to complete her assignments. The employer denied Cleveland’s request, and one week before she was awarded SSDI benefits, Cleveland filed suit against her former employer in a United States district court. There, Cleveland alleged that the employer fired her without reasonably accommodating her disability in contravention of the Americans with Disabilities Act of 1990 (ADA). To sustain her ADA claim, Cleveland asserted that she could perform the essential functions of her job with reasonable accommodations. The district court did not decide the case on the merits. Instead, the court granted summary judgment in favor of Policy Management Systems Corp. (defendant) after concluding that Cleveland was estopped from proving her ADA claim that she could perform the essential functions of her former job. The court based its conclusion on the fact that Cleveland was awarded SSDI benefits based on a claim that she was totally disabled. A court of appeals upheld the summary judgment, finding that application of the two laws presented a factual conflict. Cleveland filed a petition for writ of certiorari for a determination of whether receipt of SSDI benefits estops the recipient from simultaneously pursuing an ADA claim.