Legal Brief
US Airways Inc. v. Robert Barnett (United States Supreme Court 2001)
Type of Action
The type of action brought before the Supreme Court was an appeal from a lower court. The appellate court affirmed part of the prior decision, reversed part of the prior decision and remanded the rest. Prior to reaching the Supreme Court, the Ninth Circuit Court of Appeals heard the court (196 F.3d 979)
Facts of the Case
The facts of the case are pretty basic. An employee named Robert Barnett became disabled due to a back injury and thus requested to be transferred to a mail room position that was less demanding physically. Subsequent to that, the employee then lost that job due to be bids being made by employees who were more senior in nature. Mr. Barnett sued U.S. Airways under the Americans with Disability Act for not making proper accommodations and allowing him to keep his job (Oyez, 2014)
Contentions of the Parties
As noted in the prior section, Mr. Barnett had to take a less demanding job due to a back injury. He then lost the job under the established seniority system that existed in the firm. Mr. Barnett asserted that this was illegal as it did not protect his rights and demands of a reasonable accommodation under the Americans with Disabilities Act. U.S. Airways insisted that the use of their prior-established seniority-based bidding system did not violate the Americans with Disabilities Act and thus should not be deemed illegal (NCD, 2014).
Issue
The main issue at hand is whether an employee covered under the American Disabilities Act is thus protected from otherwise legal employer systems that allow for bidding and promotions based on things and traits that do not overtly violate the law like seniority, time in position, merit and so forth. The back injury in question suffered by Barnett did happen on the job as Barnett was a baggage handled and he was injured while on his U.S. Airways job.
Decision
Although the decision was not unanimous (7-2), it was held that the Americans with Disabilities Act hinges on the words "reasonable accommodation" and that overriding a prior-established seniority system or something similar has to be proven to be "reasonable." In essence, Mr. Barnett would have had to prove that the elimination or temporary ignorance of the agreed-upon seniority system was reasonable given the matter at hand. Indeed, Barnett initially transferred to the mailroom job using his own seniority and he then lost that same job when the job later came up for bid again. Since Barnett's bid that won the job and then the bid that lost it was under a legitimate and legal seniority system that all employees understood to be the way things worked at U.S. Airways, then the way in which Barnett gained and lost the job was in no way illegal because the decision was based on his seniority and not his disability. At the same time, the ADA does not allow for or require that a legitimate system like that be ignored as part of a reasonable accommodation (Vries, 2002).
Reasoning
The main reason it was deemed to be unreasonable to side with Barnett is because the ADA does not create an automatic exemption from policies and rules based on tenure and what-not. Indeed, Barnett used the same seniority-based system that later came back to bite him. In other words, allowing for an exception in the name of accommodation while the employee is effectively if not explicitly violating a rule that others may follow is not justifiable. This is especially true in light of the fact that Barnett used that same seniority system to his advantage. He apparently thought the seniority-based bidding system is reasonable as he used it to initially get the less demanding job. It seems he only complaining when that same system was used against him.
Rule of Law
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