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| Albertsons, Inc. v. Kirkingburg | |
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| Original jurisdiction Argued April 28, 1999 Decided June 22, 1999 | |
| Full case name | Albertsons, Inc. v. Kirkingburg |
| Citations | 527 U.S. 555 ( more ) 144 L. Ed. 518; 1999 U.S. LEXIS 4369 |
| Decision | Opinion |
| Case history | |
| Prior | Summary judgment for petitioner by the U.S. District Court for the District of Oregon; reversed by the U.S. Court of Appeals for the Ninth Circuit. |
| Outcome | |
| The U.S. Court of Appeals for the Ninth Circuit's decision was reversed. The Supreme Court held that the determination of a disability under the ADA must take into account the mitigating effects of an individual's natural adaptations. | |
| Court membership | |
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| Case opinion | |
| Majority | Souter, joined by unanimous |
| Laws applied | |
| Americans with Disabilities Act | |
In Albertsons, Inc. v. Kirkingburg, 527 U.S. 555 (1999), the United States Supreme Court considered how federal safety regulations interact with an employer's responsibilities under the Americans with Disabilities Act. The case involved Hallie Kirkingburg, a commercial truck driver with amblyopia a condition that caused him to have vision in only one eye, also known as monocular vision. Despite this condition, Kirkingburg was initially hired by Albertsons as a driver and had passed the company's vision test.
At the time, the Department of Transportation had regulations requiring commercial drivers to have binocular vision. Kirkingburg applied for and received a waiver from the DOT, allowing him to continue working as a commercial driver despite not meeting the binocular vision requirement. However, Albertsons chose not to employ him, citing adherence to the DOT's safety regulation as their reason, even though a waiver had been granted in his case.Albertsons Inc. v kirkingburg
Kirkingburg sued Albertsons under the ADA, arguing that the company had failed to provide an individualized assessment of his actual ability to perform the job, which he believed was required under the statute. The district court ruled in favor of Kirkingburg, finding that Albertsons should have evaluated his specific qualifications and not relied solely on the regulation. The Ninth Circuit Court of Appeals affirmed the lower court's decision. The Supreme Court, however, granted certiorari and reversed the decision.Albertsons Inc. v kirkingburg
The central legal issues in the case were whether an employer must defend the use of a federal safety regulation under the ADA if the regulation can be waived, and whether the ADA requires an employer to conduct an individualized assessment of a person's disability related abilities when federal regulations are involved. The Supreme Court held that an employer does not have to justify its reliance on a federal safety regulation under the ADA unless that regulation has been specifically waived in the individual's case. To add, the Court found that an individualized assessment is not required when a binding regulation is in place and has not been waived. [1]
In its reasoning, the Court emphasized that the ADA permits employers to rely on valid federal safety regulations without needing to establish additional business necessity. While the DOT does have a waiver program that allows for exceptions in certain cases, those waivers are limited, and employers are not obligated to accept or apply them when making employment decisions. The Court underscored that at the time Albertsons made its decision, the DOT's vision regulation remained in effect and had not been waived in a manner that required the company to disregard it. Therefore, Albertsons was justified in relying on the regulation, and its decision not to employ Kirkingburg did not violate the ADA.
The rule of law established by the Court in this case is that employers may rely on binding federal safety regulations as a defense under the ADA without conducting a separate analysis of business necessity or providing individualized assessments unless the regulation has been waived by the relevant federal agency in the specific case at hand.
The decision in Albertsons is significant for several reasons. First, it clarifies the relationship between federal safety regulations and the ADA, especially in situations where safety standards may appear to conflict with the ADA's requirement for equal treatment and accommodation of individuals with disabilities. Second, the ruling limits the extent to which employers must engage in individualized assessments when a valid federal rule is in place. Third, the case has had a lasting impact in the areas of employment law and disability law, particularly concerning ADA compliance in regulated industries such as transportation, where safety rules are strict and often non-negotiable.
