they are applicable, because they make it easier for a plaintiff with an episodic condition like Carmona’s to establish that he is an “individual with a disability.” See id. Carmona argued unsuccessfully in the district court that the district court needed to interpret the ADA’s definition of “disability” in light of the meaning adopted by these amendments.
On appeal, Carmona again contends that we must interpret the terms of the ADA in light of the meaning adopted by the ADA Amendments Act of 2008 (ADAAA). He also argues that, even if we decline to interpret the ADA in light of these amendments, he presented sufficient evidence for a reasonable jury to find that he was an “individual with a disability” under the old standards established by Sutton and Williams.
We begin our analysis by addressing Carmona’s argument that we should interpret the ADA’s definition of “disability” in light of the recent amendments. We have already addressed this issue generally. In EEOC v. Agro Distribution, LLC, we stated that the ADAAA did not apply retroactively. 555 F.3d 462, 469 n.8 (5th Cir. 2009). Carmona contends in his brief that he is not arguing for retroactive application of the amendments. Instead, he argues that Supreme Court precedent establishes that “[s]ubsequent legislation declaring the intent of an earlier law is entitled to great weight when it comes to statutory construction,” citing NLRB v. Bell Aerospace Co., Red Lion Broadcasting Co. v. FCC, and Glidden v. Zdanok for support. Bell Aerospace Co., 94 S.Ct. 1757 (1974), overruled on other grounds by NLRB v. Hendricks County Rural Elec. Membership Corp., 102 S.Ct. 216 (1981); Red Lion Broadcasting Co., 89 S.Ct. 1794 (1969); Glidden, 82 S.Ct. 1459 (1962). These cases are not on point. In Bell Aerospace and Red Lion Broadcasting, the meaning of the statutes at issue before the Supreme Court