Rederford v. US Airways, Inc.

In 2008, Janelle Rederford brought suit under the Americans with Disabilities Act (“ADA”) for events occurring in 2002 in federal district court against US Airways, Inc. The court dismissed the suit on the grounds that the ADA claims had been disallowed and also had been discharged as “claims” under the Bankruptcy Code in the airline’s 2003 bankruptcy. The federal court also rejected Rederford’s arguments that she was nonetheless entitled to relief based on the equitable doctrines of judicial estoppel and unclean hands. Rederford v. US Airways, Inc., 586 F. Supp. 2d 47, 51-54 (D.R.I. 2008). Rederford, who had worked for US Airways for approximately twenty-four years as a Customer Service Representative and suffered from Systemic Lupus Erythematosus (“lupus”), claimed that US Airways’ January 31, 2002, termination of her employment violated her rights under the ADA. The issues, involving the interplay between the Bankruptcy Code’s definition of “claims” and causes asserted under federal employment discrimination law, are novel for us. We affirm the dismissal.

I.