## Facts

- Carolyn Cleveland worked for Policy Management Systems Corporation performing background checks for clients.
- She suffered a stroke in January 1994 that impaired concentration, memory, and language.
- Shortly after the stroke, she applied for Social Security Disability Insurance (SSDI), stating she was disabled and unable to work.
- Her condition improved, and she returned to work in April 1994; she informed the Social Security Administration of her return.
- She alleged her employer later terminated her because of her disability.
- She filed an Americans with Disabilities Act (ADA) suit alleging she was a “qualified individual with a disability” who could perform the job’s essential functions with reasonable accommodation, while her SSDI filings asserted inability to work.

## Issues

1. Whether applying for and receiving SSDI benefits automatically estops a plaintiff from pursuing an ADA claim.
2. Whether SSDI receipt creates a strong presumption that the plaintiff is not a “qualified individual with a disability” under the ADA.
3. What a plaintiff must show at summary judgment when SSDI statements appear inconsistent with an ADA claim.

## Decision

- The Supreme Court unanimously vacated the judgment and remanded.
- Receipt of SSDI benefits does not automatically estop an ADA claim and does not create a strong presumption against ADA liability.
- An ADA plaintiff cannot ignore prior SSDI statements asserting inability to work; to defeat summary judgment, the plaintiff must provide a sufficient explanation reconciling the SSDI statements with the ADA claim.

## Legal Principles

- SSDI and ADA claims are not inherently incompatible because the Social Security Administration does not consider reasonable accommodation, while the ADA’s “qualified individual” standard does.
- Courts should not apply a special estoppel rule or presumptive bar solely from SSDI application or award.
- When an ADA claim appears to conflict with SSDI representations, the plaintiff must offer an explanation that could permit a reasonable factfinder to find the claims consistent (e.g., different legal standards or changed condition over time).
- Ordinary summary judgment standards, not categorical presumptions, govern whether the plaintiff’s explanation is sufficient.

## Conclusion

SSDI receipt does not bar an ADA discrimination suit, but a plaintiff must address and explain any apparent inconsistency between SSDI statements of inability to work and the ADA assertion that she could perform the job’s essential functions with reasonable accommodation.


Cleveland v. Policy Mgmt. Sys. Corp., 526 U.S. 795 (1999)