Sixth Circuit applies “but for” causation to ADA claims (but does it matter?)

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More than a year ago, the 6th Circuit upheld its use of a “sole reason” causation standard in ADA cases, but invited the full 6th Circuit to revisit (and overrule) this issue. That en banc panel issued its ruling last Friday, and, expectedly, it overruled the Court’s prior use of the “sole reason” causation standard. Unexpectedly, however—in Lewis v. Humboldt Acquisition Corp.(6th Cir. 5/25/12)—the Court replaced it with a similarly restrictive “but for” causation standard. But, in light of the ADA Amendments Act, does this ruling have any practical effect going forward?

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