Precedents Cited

The judgment references several key precedents that influenced the court’s decision:

• SUTTON v. UNITED AIR LINES, INC. (1999): This Supreme Court case clarified that the use of mitigating measures like accommodation devices must be considered when determining if an individual's impairment substantially limits a major life activity.
• Murphy v. United Parcel Services (1999): Reinforced the principle that even with some mitigating measures, an impairment could still qualify as a disability under the ADA.
• Albertson's, Inc. v. Kirkingburg (1999): Highlighted that auxiliary aids or reasonable accommodations do not eliminate the presence of a disability if substantial limitations remain.
• BRAGDON v. ABBOTT (1998): Established a three-step inquiry for determining disability under the ADA, which Bartlett’s case further explores.
• HEILWEIL v. MOUNT SINAI HOSPital (1994): Emphasized the broad and remedial nature of the Rehabilitation Act and the ADA.

These precedents collectively underscore the importance of a nuanced approach to determining disability, considering both the presence of impairments and the extent to which they limit major life activities, even in the presence of self-accommodations.

Legal Reasoning

The court adopted a structured approach based on ADA definitions and applicable regulations to evaluate whether Bartlett's impairment qualifies as a disability:

1. Physical or Mental Impairment: Bartlett’s dyslexia was recognized as a mental impairment, fitting within ADA’s definition of a disability.
2. Major Life Activities: The court identified "reading" and "working" as major life activities impacted by Bartlett’s impairment. While other activities like "studying" and "test-taking" were acknowledged, the focus remained on the primary claims.
3. Substantial Limitation: The critical inquiry was whether Bartlett’s impairment substantially limits her major life activities. The court emphasized that self-accommodations do not negate the presence of a disability but must be considered in assessing the extent of limitation.

The court determined that the district court had erred by considering Bartlett's self-accommodations and by using an inappropriate standard to evaluate the substantial limitation. Specifically, the district court's reliance on "roughly average reading skills on some measures" was insufficient to conclude that her reading was not substantially limited.

Regarding the major life activity of working, the district court's analysis was critiqued for not establishing a direct causal link between Bartlett’s impairment and her inability to pass the bar exam as a substantial limitation. The majority held that while the Board's regulations were appropriately applied, the district court needed to reassess causation, i.e., whether it was indeed Bartlett's impairment causing her exclusion from working, rather than other factors like education or innate ability.

Impact

This judgment has profound implications for future ADA cases, especially regarding professional licensing and reasonable accommodations:

• Clarification of Substantial Limitation: Reinforces that self-accommodations do not automatically eliminate a substantial limitation, urging courts to carefully assess the extent of impairment.
• Professional Licensing Examinations: Sets a precedent for how disabilities are evaluated in high-stakes exams, ensuring that individuals with impairments are not unfairly barred from professional advancement.
• Regulatory Interpretation: Emphasizes adherence to agency-regulated definitions and standards, highlighting the importance of the Department of Justice and EEOC regulations in ADA interpretations.
• Legal Strategy for Accommodations: Encourages litigants to present comprehensive evidence of how their impairments substantially limit their major life activities, beyond just test scores.

Overall, the decision underscores the judiciary's role in enforcing ADA protections, ensuring that individuals with disabilities receive fair treatment and necessary accommodations in professional contexts.