Supreme Court Narrows The Reach Of Disabilities Act
Since it was enacted in 1990, the federal courts have attempted to decide who is protected by the Americans with Disabilities Act ("ADA"). This judicial analysis, emerging case-by-case and without any clear consensus, has been necessary because the employment provisions of the ADA define a person with a "disability" in very general terms. The ADA declares that a "disability" is "a physical or mental impairment that substantially limits one or more of the major life activities" of an individual. Whether a person has such an impairment is critical in determining many other issues, such as whether an employer must offer "reasonable accommodation" for the employee's disability.
In December 2001, the United States Supreme Court finally decided a case that clarifies the statutory definition and the employer obligations that flow from it. In Toyota Manufacturing v. Williams, the Court narrowly read the requirement that a person's impairment must substantially limit one or more "major life activities." Writing for a unanimous Court, Justice O'Connor declared that "major life activities" refers to activities that are not merely important in performing a particular job, but are also "of central importance to daily life."
The plaintiff in the Toyota case suffered from carpal tunnel syndrome and tendonitis. Using pneumatic tools and other manual tasks on the assembly line caused her pain in her hands, wrists and arms. Accordingly, the plaintiff's personal physician placed her on permanent work restrictions that precluded her from lifting more than 20 pounds and from other activities such as "over-head work," or using "vibratory or pneumatic tools."
Thereafter, the plaintiff requested that she be allowed simply to inspect cars, without performing the other assembly and finishing tasks that would require her to lift her arms and hands above shoulder height. When that request was denied, her attendance became erratic, and she was terminated, ostensibly for her poor attendance record.
The plaintiff then sued, claiming that her employer had failed to accommodate her disability, as it was required to do by the ADA. After a ruling against her in the trial court, the plaintiff prevailed before the federal appeals court. In accordance with many lower court decisions, the appeals court ruled the plaintiff had a disability, because her physical condition "substantially limited her ability to perform the range of manual tasks associated with an assembly line job."
The Supreme Court took an entirely different approach. Rather than focusing only on how the plaintiff's impairment affected her ability to perform manual tasks in the workplace, the Court broadened the inquiry. To be substantially limited in performing manual tasks, the Court reasoned, an individual must show that the impairment prevents or severely restricts her "from doing activities that are of central importance to most people's daily lives." Such essential activities include "household chores, bathing, and brushing one's teeth...." The Court also emphasized that to be an impairment recognized by the ADA, the condition cannot be temporary, but must be permanent or long-term.
What does the Court's decision mean for employers and employees with impairments? Clearly, impaired employees can no longer assume that they will be entitled to protection under the ADA simply because a doctor has opined that they are limited in their ability to perform certain tasks required by their job. Nor must employers take such opinions as the final word on whether they are required to accommodate an employee's impairment. Rather, the impact of the impairment on the employee's daily activities both in and outside the workplace must be considered. The ADA covers not just "employees" but "individuals," whose lives are not summed up merely by their work tasks and requirements.
The first step in the approach suggested by the Court is still to identify and consider the specific tasks and activities the employee may be restricted in performing. But these tasks can no longer be limited to activities required at work, much less to those demanded by a particular job. The impairment now must have a broader effect, significantly limiting an individual's functions that are of "central importance" to people's daily lives. As a spokesman for the National Association of Manufacturers put it, "This ruling makes it clear that the ADA is still the Americans with Disabilities Act, not the Americans with Injuries Act."