Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

contractappealdiscriminationrehabilitation
contractappealrehabilitation

Related Cases

Collins v. Braden, 384 S.W.3d 154
View Case »
McBride v. United States, 255 A.3d 1022
View Case »
Reda v. Advocate Health Care, 199 Ill.2d 47, 765 N.E.2d 1002, 262 Ill.Dec. 394
View Case »
McCall v. United States, 143 S.Ct. 2506 (Mem), 216 L.Ed.2d 461
View Case »
Adams v. Laboratory Corp. of America, 760 F.3d 1322, 25 Fla. L. Weekly Fed. C 197
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Arline v. School Bd. of Nassau County, 772 F.2d 759, 39 Fair Empl.Prac.Cas. (BNA) 9, 38 Empl. Prac. Dec. P 35,612, 54 USLW 2212, 27 Ed. Law Rep. 675

Facts

Mrs. Gene Arline contracted tuberculosis at a young age, went into remission, and worked as a competent elementary school teacher for thirteen years. After suffering multiple relapses, the Nassau County School Board dismissed her due to concerns about her contagious disease. Arline argued that her susceptibility to tuberculosis made her a 'handicapped individual' under the Rehabilitation Act and that the school board failed to provide reasonable accommodations for her continued employment.

Mrs. Gene Arline first contracted tuberculosis in 1957 at the age of fourteen, after which the disease went into remission. In 1966 she was hired as an elementary school teacher in Nassau County, Florida, and did her job competently for thirteen years. Arline then suffered three relapses of tuberculosis, one in 1977 and two in 1978. After her third relapse, the School Board dismissed Arline from her job.

Issue

Did the dismissal of Mrs. Arline due to her susceptibility to tuberculosis violate the Rehabilitation Act, and does tuberculosis constitute a 'handicap' under the Act?

The Court of Appeals, Vance, Circuit Judge, held that: (1) contagious disease of tuberculosis constituted a 'handicap' within meaning of the Rehabilitation Act, and (2) remand was required for further findings as to whether risks of infection precluded teacher from being otherwise qualified for her job.

Rule

Under the Rehabilitation Act, a 'handicapped individual' is defined as someone with a physical or mental impairment that substantially limits one or more major life activities, and employers must provide reasonable accommodations for otherwise qualified individuals.

In enacting the Rehabilitation Act of 1973, Congress designed a comprehensive federal program aimed at integrating the handicapped into this society and affording them greater access to its benefits.

Analysis

The Court of Appeals found that the district court misinterpreted the definition of 'handicap' by excluding contagious diseases like tuberculosis. The court emphasized that the Rehabilitation Act aims to prevent discrimination against individuals with disabilities and that the school board's decision to dismiss Arline without considering reasonable accommodations was not justified. The court noted that the risks associated with her employment should have been carefully weighed against the possibility of accommodating her condition.

We therefore remand this case for further findings as to whether the risks of infection precluded Mrs. Arline from being 'otherwise qualified' for her job and if so whether it was possible to make some reasonable accommodation for her in that teaching position, in another position teaching less susceptible individuals, or in some other kind of position in the school system.

Conclusion

The Court of Appeals reversed the district court's decision and remanded the case for further findings regarding whether Arline was otherwise qualified for her job and if reasonable accommodations could be made.

REVERSED and REMANDED.

Who won?

The Court of Appeals ruled in favor of Mrs. Arline, stating that her dismissal was discriminatory under the Rehabilitation Act.

The Court of Appeals ruled in favor of Mrs. Arline, stating that tuberculosis is indeed a handicap and that the school board's decision to dismiss her without considering reasonable accommodations was discriminatory.

You must be