Employee’s Statements on SSDI Application May Preclude ADA Claim
An employee’s assertions of complete disability on her application for Social Security Disability benefits barred her claim under the Americans with Disabilities Act, according to the U.S. Court of Appeals for the First Circuit.
In Pena v. Honeywell Int’l, Inc., following her exhaustion of medical leave and resulting termination, the employee applied for SSDI benefits, stating, “I became unable to work because of my disabling condition…” and “I am still disabled.” She also sued her employer for violating the ADA.
In order to sustain a claim under the ADA, the employee must show not only that she is disabled, but that she is “qualified,” meaning that she is able to perform the essential functions of her job, with or without a reasonable accommodation. The U.S. Supreme Court has previously addressed the interaction between an employee’s application for SSDI benefits and an ADA claim, in Cleveland v. Policy Mgmt. Syst. Corp. According to the Supreme Court, an application for SSDI benefits does not necessarily doom an ADA claim, because there are different standards for each of those laws. Rather, it is necessary for the employee to explain any inconsistencies in any SSDI statements regarding the employee’s inability to work and her ADA claim.
The First Circuit rejected the employee’s argument that it was sufficient for her simply to state that SSDI is different from the ADA. Rather, the First Circuit noted that she needed to offer a “reasoned explanation” for her SSDI statements, which she failed to do (particularly noting that she had been represented by counsel in both proceedings). Thus, as this case illustrates, an employee may be held accountable for her SSDI statements to the extent that such statements may undercut an ADA claim and the employee has no reasoned explanation for the discrepancy.