ADA claim in Washington

7 Washington opinions name it 1 courts 1999–2025 2 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (2)

Case	Followed	Cited
Dolores Tarin v. County of Los Angeles Robert C. Gates, Irwin Silberman, Dr.green ca9 · 1997 · cited in 1 Washington opinions naming this issue, 2016–2016 2 sentences 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53. 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53.	1	1
Emily Snead v. Metropolitan Property & Casualty Insurance Company, a Delaware Corporation James McIntoshgreen ca9 · 2001 · cited in 1 Washington opinions naming this issue, 2016–2016 2 sentences 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53. 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (11)

Case	Cited	Years
Cleveland v. Policy Management Systems Corp. green scotus · 1999 2 sentences 2025To survive a defendant’s motion for summary judgment, she must explain why that SSDI contention is consistent with her ADA claim that she could “perform the essential functions” of her previous job, at least with “reasonable accommodation.” 526 U.S. 795, 797-98 , 119 S. Ct. 1597 , 143 L. 2025To survive a defendant’s motion for summary judgment, she must explain why that SSDI contention is consistent with her ADA claim that she could “perform the essential functions” of her previous job, at least with “reasonable accommodation.” 526 U.S. 795, 797-98 , 119 S. Ct. 1597 , 143 L.	1	2025–2025
Panag v. Farmers Insurance green wash · 2009 2 sentences 2024Co. of Wash., 166 Wn.2d 27, 37 , 204 P.3d 885 (2009) (citing Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. 2024Co. of Wash., 166 Wn.2d 27, 37 , 204 P.3d 885 (2009) (citing Hangman Ridge Training Stables, Inc. v. Safeco Title Ins.	1	2024–2024
Panag v. Farmers Ins. Co. of Washington green wash · 2009 2 sentences 2024Co. of Wash., 166 Wn.2d 27, 37 , 204 P.3d 885 (2009) (citing Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. 2024Co. of Wash., 166 Wn.2d 27, 37 , 204 P.3d 885 (2009) (citing Hangman Ridge Training Stables, Inc. v. Safeco Title Ins.	1	2024–2024
Lynn v. Department of Social & Health Services neutral washctapp · 2012 2 sentences 2020To prevail on an ADA claim against a public entity, a plaintiff must show “(1) he is a qualified individual with a disability; (2) he was either excluded from participation or denied the benefits of a public entity’s services, programs or activities, or was otherwise discriminated against by the public entity; and (3) such exclusion, denial of benefits, or discrimination was by reason of his disability.” Lynn v. Dept of Soc. & Health Servs., 170 Wn. 2020To prevail on an ADA claim against a public entity, a plaintiff must show “(1) he is a qualified individual with a disability; (2) he was either excluded from participation or denied the benefits of a public entity’s services, programs or activities, or was otherwise discriminated against by the public entity; and (3) such exclusion, denial of benefits, or discrimination was by reason of his disability.” Lynn v. Dept of Soc. & Health Servs., 170 Wn.	1	2020–2020
Milstead v. Kibler green scotus · 2001 2 sentences 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53. 2016Co., 237 F.3d 1080, 1093 (9th Cir.) (applying Title VII analysis to an ADA claim), cert. denied, 534 U.S. 888 (2001); Tarin v. County of Los Angeles, 123 F.3d 1259, 1264 (9th Cir. 1997) (applying Title VII’s analysis to a § 1981 claim). 8 Emeson also asserts that “it is highly speculative and dubious that any claims pursuant to RCW 49.60 necessarily ‘could have’ been pursued in the above-referenced dismissed district court action.’’ Br. of Appellant at 52-53.	1	2016–2016
School Bd. of Nassau Cty. v. Arline green scotus · 1987 2 sentences 2015In the first of the two decisions, School Board ofNassau County v. Arline, 480 U.S. 273 (1987), the nation's high Court allowed a teacher with tuberculosis to proceed with an ADA claim despite the school district's fear that she may infect students with the 41 No. 32879-I-II1 Kries v. WA-SPOK Primary Care, LLC disease. 2015In the first of the two decisions, School Board ofNassau County v. Arline, 480 U.S. 273 (1987), the nation's high Court allowed a teacher with tuberculosis to proceed with an ADA claim despite the school district's fear that she may infect students with the 41 No. 32879-I-II1 Kries v. WA-SPOK Primary Care, LLC disease.	1	2015–2015
Wisland v. Admiral Beverage Corp. green scotus · 1998 2 sentences 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L. 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L.	1	1999–1999
Cochrane v. Tudor Oaks Ltd. Partnership green scotus · 1998 2 sentences 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L. 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L.	1	1999–1999
City of Mount Vernon v. Stone green scotus · 1998 2 sentences 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L. 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L.	1	1999–1999
Stone v. City of Mount Vernon green ca2 · 1997 2 sentences 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L. 1999Ed. 2d 407 (1993) (clarifying the McDonnell Douglas burden-shifting scheme). 10 In contrast, Dedman had worked in the control booth for a relatively short time, less than two years. 11 Dedman has not filed an ADA claim, although she concedes that the ADA can be used to interpret WLAD. 12 Contrary to Dedman’s contention, Stone v. City of Mount Vernon, 118 F.3d 92 (2d Cir. 1997), cert. denied, 522 U.S. 1112 , 118 S. Ct. 1044 , 140 L.	1	1999–1999
Dennis E. Gaul v. Lucent Technologies Inc. John Does 1-100 Jane Does 1-100 Abc Corp. Xyz Corp green ca3 · 1998 2 sentences 1999Gaul v. Lucent Techs., Inc., 134 F.3d 576 (3d Cir. 1998). 1999Gaul v. Lucent Techs., Inc., 134 F.3d 576 (3d Cir. 1998).	1	1999–1999

Statutes the citing opinions construe

WA § Wash. Rev. Code § 49.60.180 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 50 (1997–2025) CO 23 (1996–2026) TX 18 (1998–2021) MI 17 (1998–2026) NY 12 (1992–2025) NJ 10 (1997–2025) AZ 9 (1999–2025) CT 9 (1999–2022) IL 9 (1995–2021) MD 8 (2000–2025) NM 8 (1997–2025) NC 8 (2000–2017) OH 8 (1999–2022) WA 7 (1999–2025) KS 6 (2000–2017) IN 6 (2008–2018) MA 6 (1999–2024) IA 6 (1999–2018) PA 6 (2003–2026) MO 5 (2005–2025) WV 5 (1997–2019) LA 5 (1997–2021) AL 5 (1998–2013) MN 4 (1999–2026) UT 4 (2002–2022) ME 4 (2002–2023) TN 4 (1999–2006) VT 3 (2006–2026) HI 3 (2001–2002) VA 3 (2022–2026) FL 3 (2004–2013) MT 3 (2004–2016) GA 3 (2010–2021) NE 2 (2015–2015) DC 2 (2000–2001) WI 2 (2000–2007) ND 2 (2003–2009)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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