Mohamed v. Marriott International, Inc.
Ahmed Mohamed, a profoundly deaf individual, sued Marriott International, Inc. and Marriott Corporation under the Americans With Disabilities Act (ADA) and New York State Human Rights Law for wrongful discharge. Marriott moved for summary judgment, arguing Mohamed should be judicially estopped from asserting an ADA claim because he had previously applied for Social Security Disability Insurance Benefits (SSDI), stating he was unable to work. The court denied Marriott's motion. It ruled that judicial estoppel was inappropriate given the differing legal standards between ADA and SSDI, the nature of SSDI administrative determinations (paper application for a listed disability), and the policy goals of the ADA which encourage disabled individuals to seek employment. The court found ample evidence that Mohamed was able to perform the essential functions of his job.