Cody v. Cigna Healthcare of St. Louis, Inc.’s Empirical Analysis
139 F.3d 595 · 1998
Citation profile
27 federal appellate · 8 district · 2 state decisions
How this case has been cited
Cited by 76 later decisions — most recently May 2020 · most notably Silk v. City of Chicago (1999), Sullivan v. River Valley School District (1999)
27 federal appellate · 8 district · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 42 U.S.C. § 12101 (§ 2 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12102 (§ 3 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12112 (§ 102 of the Americans with Disabilities Act of 1990)
Relies on Henderson v. Brown · Aucutt v. Six Flags Over Mid-America, Inc. · Palmer v. Circuit Court of Cook County · Price v. S-B Power Tool · Miller v. National Casualty Co.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An employer’s request for a mental evaluation is not inappropriate if it is not obvious that an employee suffers from a disability. A request for an evaluation is not equivalent to treatment of the employee as though she were substantially impaired. Employers need to be able to use reasonable means to ascertain the cause of troubling behavior without exposing themselves to ADA claims under §§ 12112(a) and 12102(2)(C).”
14 later decisions quote this exact passage · from the majority“(A) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (B) a record of such impairment; or (C) being regarded as having such an impairment.”
4 later decisions quote this exact passage · from the majority““[T]he EEOC uses a specialized definition of the term ‘substantially limits’ when referring to the major life activity of working: ‘significantly restricted in the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities. The inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working.’ ””
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.