Realbuto v. Howe
Lori Boyar Realbuto, a former New York State employee with a hearing impairment and chronic fatigue immunity deficiency syndrome, sued New York State and several officials, alleging discrimination based on her handicaps. She claimed violations of Section 504 of the Rehabilitation Act of 1973, the Americans With Disabilities Act, and the due process and equal protection clauses, after her noncompetitive "55-b" position was eliminated during a reduction-in-force, preventing her from "bumping" a more junior competitive class employee. The Court granted the defendants' motion for summary judgment, finding that Realbuto failed to demonstrate discrimination "solely" on the basis of her handicap, as her inability to bump resulted from her classification as a noncompetitive employee who did not take a competitive examination, rather than her disability itself. The Court also dismissed her equal protection and due process claims, finding the civil service classification rational and no protected interest in the claimed benefits.