Robert Pinkerton, a visibly disabled employee terminated by the Department of Education, sued under Sections 501 and 504 of the Rehabilitation Act alleging disability discrimination. After a jury verdict for the agency, Pinkerton appealed, arguing the jury instructions used the wrong legal standard. The Fifth Circuit held that Section 501 claims by federal employees incorporate the ADA's causation standard, under which a plaintiff need only show that disability was a motivating factor in the adverse action rather than the sole cause. Because the district court's charge required the stricter "solely because of" proof, the court reversed the judgment and remanded for a new trial.

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