Can Teamsters Be Applied in ADA Cases?
The dispute over whether the Teamsters framework should be applied in this case involves two questions, Scirica said–whether the framework “can be imported from the Title VII context in which it was promulgated and applied to pattern-or-practice claims raised under the ADA” and, if so, whether the UPS employees’ claims can be certified for class treatment. The Teamsters framework “might assist a court’s analysis of whether a defendant has engaged in a pattern or practice of discrimination” and “to whom relief should be awarded,” but it is the underlying discrimination statute that “defines the scope of prohibited discrimination and sets the substantive boundaries within which the method of proof must operate,” Scirica said. Under the framework, the UPS employees have the burden of showing that the company adopted a pattern or practice of discrimination prohibited by the ADA, Scirica said. He pointed out that the ADA prohibits discrimination against a “qualified individual with a disab
