Williams v. Philadelphia Housing Authority Police Department
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Courts continue to apply Williams's retaliation analysis. All 47 flagged citations have been read; the 2 confirmed treatments are listed below.
47 later cases cite Williams v. Philadelphia Housing Authority Police Department; 47 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 Williams v. Philadelphia Housing Authority Police Department?
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
Superseded by Statute
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The 2008 ADA amendments ended Williams's rule that an employee regarded as disabled is entitled to a reasonable accommodation.
Robinson v. First State Community Action Agency · Third Circuit · filed
The instructions given to the jury below modified those in Williams to reflect the entitlement of a “regarded as” plaintiff to a reasonable accommodation. Those instructions correctly explained the law under our precedent in Williams, but the 2008 Amendments abrogated Williams on that point.
Read the full opinion on CourtListener → -
The amended ADA displaced Williams's requirement that an employer regard an employee as substantially limited in a major life activity.
Scott v. Blossburg Borough · M.D. Pa. · filed
The parties’ confusion stems from the pre- and post-amendment versions of the ADA. Congress amended the ADA in 2008, and specifically changed the definition of a “regarded as” disability. Pre-2008 amendments required that a plaintiff show that the employer regarded the employee as having a disability that substantially limited the plaintiff’s major life activities. See Williams v. Phila. Hous. Auth. Police Dept., 380 F.3d 751, 767 (3d Cir. 2004). However, the text of the statute now specifically rejects this definition, providing that an individual is regarded as having such an impairment, “if the individual establishes that he or she has been subjected to an action prohibited under this chapter because of an actual or perceived physical or mental impairment whether or not the impairment limits or is perceived to limit a major life activity.”
Read the full opinion on CourtListener →
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