- The American Disability Amendments Act of 2008 Does Not Apply to Claims Prior to January 1, 2009
- August 10, 2009 | Author: Paul N. Farquharson
- Law Firm: Semmes, Bowen & Semmes, A Professional Corporation - Baltimore Office
Lytes v. D.C. Water and Sewer Authority, No. 08-7002, 2009 WL 2152427 (D.C. Cir. July 21, 2009)
In Lytes v. D.C. Water and Sewer Authority, Floyd Lytes brought an action against his employer, the District of Columbia Water and Sewer Authority (the "Authority"), under the American with Disabilities Act of 1990 ("ADA"). In this action, Lytes, a plant operator, claimed that the Authority's alleged refusal to accommodate his disability and their subsequent termination of his employment was in violation of the ADA. Specifically, Lytes claimed that the Authority failed to provide reasonable accommodations for his mild physical limitations in squatting, bending, ladder climbing, and overheard reaching.
Initially, Lytes used these allegations to support a disability discrimination claim before the Equal Employment Opportunity Commission, which was dismissed. Shortly thereafter, Lytes brought suit against the Authority claiming, among other things, that the Authority violated the ADA by failing to provide reasonable accommodations for his disability and by ultimately terminating his position.
On these issues, the District Court for the District of Columbia rejected Lytes' theory that his work restriction and limitations constituted a disability within the meaning of the ADA. To survive summary judgment under the ADA, the court noted that Lytes had to show that he suffered from an impairment that substantially limited him in major life activity during the time the Authority allegedly discriminated against him. Although the court found no dispute as to the existence of Lytes' physical impairment during the relevant time, the court stated that Lytes' restrictions on lifting, bending, and working were not limitations on "major life activities." Moreover, Lytes had stated that his medical conditions had improved to the point where he could work at light-level duty with minimal discomfort. Therefore, Lytes could not show that his disability lead to substantial impairments in at least one major life activity as required by the ADA. The court granted summary judgment for the Authority and Lytes appealed.
While Lytes' appeal was pending, Congress enacted the ADA Amendments Act of 2008 ("ADAAA"), which broadened the definition of what constituted a "disability" for the purposes of an ADA claim. In its review of Lytes' appeal, the appellate court sought to answer two questions: first, whether the ADA Amendments Act of 2008 applied retroactively to Lytes' claims; and second, whether Lytes was disabled when he was allegedly refused accommodation and subsequently discharged.
In seeking to determine whether Lytes had a "disability" within the meaning of the ADAAA and/or the ADA, the appellate court rejected Lytes' argument that the Authority's refusal to accommodate his position was unlawful under the new, broad ADAAA. Holding that Congress' delay of the ADAAA's effective date demonstrated that the statute could only operate prospectively, the Court determined that Lytes' failure to present any evidence indicating a contrary interpretation meant that he could not meet his burden and did not overcome the court's presumption against applying statutes retroactively. Therefore, the ADAAA did not govern Lytes's suit for retrospective damages, and the court reviewed Lytes' appeal under the standards set forth by the ADA. The appellate court, like the District Court , found that the evidence of Lytes' condition during the relevant time did not constitute a "disability" within the meaning of the ADA. Therefore, summary judgment was affirmed.
In Lytes, the appellate court affirmed summary judgment in an ADA action because no reasonable jury could find that plaintiff was disabled within the meaning of the ADA when his employer allegedly refused to provide reasonable accommodation and ultimately discharged him. In so doing, the court reaffirmed its reluctance to apply statutes retrospectively. By applying pre-ADAAA standards for what constitutes a "disability" to the issue at hand, the court made clear that for claims arising before the ADAAA's effective date will be judged by the more narrow ADA definition of a "disability."