[JURIST] The US Court of Appeals for the Sixth Circuit [official website] ruled [opinion, PDF] Friday that an employee with a claim under the Americans with Disabilities Act (ADA) [text] does not need to show that his or her disability was the sole reason he or she was fired, only that the disability was a "but-for" cause of the termination. This decision overturns 17 years of precedent in that circuit, which the appeals court now says was followed because of confusion about the meaning of the case Maddox v. University of Tennessee [opinion]. That case involved both a claim under the ADA and one under the Rehabilitation Act, which does expressly require that termination be based "solely" on a person's disability. The appeals court decided in the current case, Lewis v. Humboldt Acquisition Corp., that, because the ADA does not use the word "solely" in the relevant provision like the Rehabilitation Act does, it was intended that the ADA be applicable whenever disability was a necessary factor in an employer's decision to fire an employee.
The ADA has been the subject of much case law and has been amended since its adoption in 1990 [JURIST report]. In 2008 the US Congress amended the act [JURIST report] to make it easier for employees to bring a claim under the law, closing gaps that could have denied protection to employees with certain disabilities. At that time, Congress said the amendments were necessary to remedy the US Supreme Court's restrictive interpretation of the law in Toyota Motor Manufacturing, Kentucky Inc. v. Williams [opinion] in 2002. The Supreme Court also ruled in 2006 that states have no immunity [JURIST report] under the ADA and must comply with its standards.