The number of suits alleging disability discrimination dropped in fiscal years 1999 (54 filed; Table V) and 2000 (25 filed; Table VI) from a high in fiscal years 1997 (83; Table III) and 1998 (85; Table IV). This drop is directly related to the Supreme Court's decisions in June 1999 in Sutton v. United Airlines; Murphy v. UPS and Albertsons, Inc. v. Kirkingburg, in which the Court narrowed the definition of disability by requiring mitigating measures to be considered in determining whether an individual has a "substantially limiting" impairment. Thus, for example, an individual with insulin dependant diabetes, historically considered disabled, might not be "disabled" under the Supreme Court's interpretation of the statute if the individual is able to control his/her diabetic condition with the insulin. In the aftermath of these three decisions, the agency refocused its efforts and analysis of Americans with Disability Act (ADA) cases and has gradually rebuilt the ADA litigation program. In FY 2001 (Table VII), OGC filed 64 suits alleging disability discrimination; 39 more than the previous fiscal year.