Narrative Opinion Summary
The case of Bartlett v. New York State Board of Law Examiners involves a dispute over whether the plaintiff, Marilyn J. Bartlett, qualifies as having a disability under the Americans with Disabilities Act (ADA) due to dyslexia. The U.S. Court of Appeals for the Second Circuit examined the district court's ruling that Bartlett was not substantially limited in major life activities such as reading or learning, but was limited in her ability to work, thus requiring reasonable accommodations for the bar examination. The appellate court affirmed in part, vacated in part, and remanded for further consideration of Bartlett's disability status concerning reading and working. The Supreme Court later granted certiorari and remanded the case, clarifying that Bartlett's self-accommodations should not be the sole factor in determining her disability status and that her reading impairment might substantially limit her compared to most people. The court also emphasized that substantial limitations must be proven, particularly regarding the major life activity of working. The district court was instructed to evaluate if Bartlett's slow reading limits her compared to the general population and if her impairment restricts her from a class of jobs in the legal field. Bartlett's claim for damages and accommodations based on ADA violations was considered, with further proceedings required to determine appropriate relief.
Legal Issues Addressed
Consideration of Self-Accommodations under the ADAsubscribe to see similar legal issues
Application: The court ruled that the district court improperly considered Bartlett's ability to self-accommodate when assessing her reading limitations under the ADA.
Reasoning: It ruled that the district court improperly considered Bartlett's ability to self-accommodate when assessing her reading limitations under the ADA.
Definition of Disability under the ADAsubscribe to see similar legal issues
Application: The court clarifies that a disability includes any physical or mental impairment that substantially limits one or more major life activities.
Reasoning: The court clarified that a disability includes any physical or mental impairment that substantially limits one or more major life activities.
Impact of Impairment on Employmentsubscribe to see similar legal issues
Application: The court emphasized the need for proof that the impairment substantially limits the major life activity of working, not just implicates it.
Reasoning: The court disagreed with the district court's analysis regarding Bartlett's ability to work, emphasizing that proving an impairment 'implicates' a major life activity is insufficient; there must be proof that the impairment 'substantially limits' that activity.
Legal Standards for Determining Disabilitysubscribe to see similar legal issues
Application: The Supreme Court remanded the case to assess whether Bartlett's reading speed or conditions impose a substantial limitation compared to most people.
Reasoning: The Supreme Court remanded the case for the district court to assess whether Bartlett's slow reading speed or other conditions impose a substantial limitation on her reading compared to most people.
Substantial Limitation in Major Life Activitiessubscribe to see similar legal issues
Application: The court highlighted that having average skills on some measures does not negate substantial limitations in reading overall.
Reasoning: The court pointed out that having average skills on some measures does not negate substantial limitations in reading overall, especially given the district court's findings about Bartlett's slow and laborious reading.