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A Better Partnership


Jan 2002
January 01, 2002

United States Supreme Court Clarifies and Limits ADA Definition of Disability

In a decision that may signal a dramatic limitation on disability claims under the Americans with Disabilities Act, the United States Supreme Court has clarified the rules for determining when an individual is disabled under the Americans with Disabilities Act ("ADA"). In Toyota Motor Manufacturing v. Williams, Ms. Williams sued Toyota for failing to accommodate her carpal tunnel syndrome and related conditions. Ms. Williams claimed that she was disabled because her physical impairments made her unable to perform the manual tasks associated with her assembly line job for Toyota. The Sixth Circuit Court of Appeals had agreed with Ms. Williams and entered judgment in her favor, but the Supreme Court reversed.

The Supreme Court considered when a limitation in the ability to perform manual tasks would rise to the level of a disability under the ADA. The Supreme Court focused on the ADA's definition of "disability" -- "a physical or mental impairment that substantially limits one or more . . . major life activities" and held that the terms "substantial" and "major" must be interpreted strictly to create a demanding standard for qualifying as disabled under the ADA. A unanimous Supreme Court ruled that "to be substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives. The impairment's impact must also be permanent or long-term."

When an individual claims that he or she is disabled because of a limitation in performing manual tasks, the Supreme Court held that a court must look at whether the person is unable to perform the variety of tasks central to most people's daily lives, such as tending to personal hygiene and doing household chores, and not simply whether the person is unable to perform the tasks associated with a specific job. This is because the manual tasks unique to any particular job are not likely to be important parts of most people's lives and are therefore not "major" life activities. The fact that Ms. Williams was unable to do repetitive work with her hands and arms extended at or above shoulder level for extended periods of time was not enough to prove that she was disabled, because the evidence showed that she could still carry out personal and household chores, such as bathing, brushing her teeth, fixing breakfast, doing laundry and picking up around the house.

This decision is important for a number of reasons. The Supreme Court's ruling will have immediate and direct impact on employers who deal with disability claims arising out of repetitive motion disorders. The Supreme Court's language is much more far-reaching, however. The Supreme Court made it clear that it will narrowly interpret the term "disability" under the ADA and hold plaintiffs to a rigorous standard for proving that they are disabled. In addition, the Supreme Court hinted that it may not give deference to the EEOC's regulations interpreting the term "disability" and that it may not consider working to be a major life activity under the ADA. The fact that the Toyota v. Williams decision was unanimous, which is unusual in itself, only bolsters the conclusion that the Supreme Court is open to more significant restrictions on ADA claims. The Supreme Court will soon be issuing decisions in other ADA cases that may also have far-reaching impact. Stay tuned!

For more information, contact your WN&J attorney.

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