OCTOBER TERM, 2001
Syllabus
certiorari to the united states court of appeals for the ninth circuit
No. 00-1250. Argued December 4, 2001—Decided April 29, 2002
After respondent Barnett injured his back while a cargo handler for petitioner US Airways, Inc., he transferred to a less physically demanding mailroom position. His new position later became open to seniority-based employee bidding under US Airways' seniority system, and employees senior to him planned to bid on the job. US Airways refused his request to accommodate his disability by allowing him to remain in the mailroom, and he lost his job. He then filed suit under the Americans with Disabilities Act of 1990 (ADA or Act), which prohibits an employer from discriminating against "an individual with a disability" who with "reasonable accommodation" can perform a job's essential functions, 42 U. S. C. §§ 12112(a) and (b), unless the employer "can demonstrate that the accommodation would impose an undue hardship on the operation of [its] business," § 12112(b)(5)(A). Finding that altering a seniority system would result in an "undue hardship" to both US Airways and its nondisabled employees, the District Court granted the company summary judgment. The Ninth Circuit reversed, holding that the seniority system was merely a factor in the undue hardship analysis and that a case-by-case, fact intensive analysis is required to determine whether any particular assignment would constitute an undue hardship.
Held: An employer's showing that a requested accommodation conflicts with seniority rules is ordinarily sufficient to show, as a matter of law, that an "accommodation" is not "reasonable." However, the employee remains free to present evidence of special circumstances that makes a seniority rule exception reasonable in the particular case. Pp. 396-406.
(a) Many lower courts have reconciled the phrases "reasonable accommodation" and "undue hardship" in a practical way, holding that a plaintiff/employee (to defeat a defendant/employer's summary judgment motion) need only show that an "accommodation" seems reasonable on its face, i. e., ordinarily or in the run of cases. The defendant/employer then must show special (typically case-specific) circumstances demonstrating undue hardship in the particular circumstances. Neither US Airways' position—that no accommodation violating a seniority system's rules is reasonable—nor Barnett's position—that "reasonable accommodation" authorizes a court to consider only the requested accom-
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