Case Citator › Roger Monette and Doris Monette v. Electronic Data Systems Corporation

Roger Monette and Doris Monette v. Electronic Data Systems Corporation

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Sixth Circuit
Citation
90 F.3d 1173
Decided
Confirmed treatments
1
Flagged citations read
89 of 89
Citing cases (total)
740
Treatment dates
2012
Overruled in part
A reviewed court has overruled part of this case’s holding. Roger Monette and Doris Monette v. Electronic Data Systems Corporation has been overruled in part: all 89 flagged citations have been read, and the confirmed treatment is listed below. Sitting en banc, the Sixth Circuit held in Lewis v. Humboldt Acquisition Corp. that Monette wrongly imported the Rehabilitation Act's sole-cause requirement into the ADA; an ADA claimant instead must prove but-for causation.
More on how this was screened

Lewis did not disturb Monette's separate prima-facie, direct-evidence, reasonable-accommodation, or undue-hardship rules, which the reviewed opinions continued to apply. Most citing opinions reported Lewis's act in an “abrogated on other grounds” parenthetical rather than treating Monette themselves. Four opinions whose text was at first unavailable were later retrieved and followed surviving rules. The 2011 Lewis panel opinion and one Ford Motor Co. panel were vacated and produced no treatment.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

740 later cases cite Roger Monette and Doris Monette v. Electronic Data Systems Corporation; 89 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Roger Monette and Doris Monette v. Electronic Data Systems Corporation?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The en banc Sixth Circuit overruled Monette's rule that an ADA plaintiff must prove disability was the sole cause of an adverse employment action, holding that the statute instead requires but-for causation.

    Lewis v. Humboldt Acquisition Corp., Inc. · Sixth Circuit (en banc) · filed

    Consistent with Maddox, we used the “solely” standard in an ADA-only claim a year later, Monette v. Electronic Systems Corporation, 90 F.3d 1173, 1177-78 (6th Cir.1996), and before long that became the standard for relief under the ADA in this circuit, see, e.g., Macy v. Hopkins County Sch. Bd. of Educ., 484 F.3d 357, 363-64 (6th Cir.2007); Cotter v. Ajilon Servs., Inc., 287 F.3d 593, 598 (6th Cir.2002). The longer we have stood by this standard, the more out of touch it has become with the standards used by our sister circuits. At this point, no other circuit imports the “solely” test into the ADA. See Katz v. City Metal Co., 87 F.3d 26, 33 (1st Cir.1996); Parker v. Columbia Pictures Indus., 204 F.3d 326, 337 (2d Cir.2000); Shellenberger v. Summit Bancorp, Inc., 318 F.3d 183, 187 (3d Cir.2003); Baird v. Rose, 192 F.3d 462, 468-69 (4th Cir.1999) (Title II case); Pinkerton v. Spellings, 529 F.3d 513, 519 (5th Cir.2008); Serwatka v. Rockwell Automation, Inc., 591 F.3d 957, 963 (7th Cir.2010); Pedigo v. P.A.M. Transp., Inc., 60 F.3d 1300, 1301 (8th Cir. 1995); Head v. Glacier Northwest, Inc., 413 F.3d 1053, 1065 (9th Cir.2005); Bones v. Honeywell Int’l, Inc., 366 F.3d 869, 878 (10th Cir.2004); McNely v. Ocala Star-Banner Corp., 99 F.3d 1068, 1074 (11th Cir.1996); Adeyemi v. Dist. of Columbia, 525 F.3d 1222, 1226 (D.C.Cir.2008). Our interpretation of the ADA not only is out of sync with the other circuits, but it also is wrong.
    Read the full opinion on CourtListener →

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