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Abstract :
[en] Some scholarly works have highlighted the diffusion of the US disability rights model in Europe, considering that a disability rights’ revolution was underway. They have also identified sources of resistance to the diffusion of this “civil rights’ frame” to address disability issues in Europe (Burke, 2004; Heyer, 2002; Vanhala, 2011; Waldschmidt, 2009).
Focusing on legal mobilizations against disability discrimination in the workplace, I analyze and compare how government agencies (the Swedish Ombudsman against discrimination and the US Equal Employment Opportunity Commission), as well as non-governmental organizations in both countries, address these issues. How do the structures of national institutions frame legal mobilizations against disability discrimination in each country? Do they tend to converge in the way they mobilize the law to address these issues?
Through investigative techniques consisting primarily of open-ended interviews with lawyers working in NGOs and in government agencies for equality in the United States and in Sweden, I highlight several challenges faced by studies on disability rights, especially when they describe and explain convergence of legal mobilizations, and try to offer suggestions for overcoming these challenges. More broadly, this contribution aims to call into question the processes of transnationalisation and policy transfer from one country to another.