U.S. Supreme Court Narrows ADA Protection: Inability to Perform Work Tasks Alone is Not a Disability Under the Americans With Disabilities Act

Toyota Motor Manufacturing, Kentucky, Inc. v. Williams

A recent decision by the United States Supreme Court narrows the reach of the Americans with Disabilities Act and could be a victory for some employers faced with ADA discrimination claims. The ADA requires reasonable accommodation for known physical or mental limitations of an otherwise qualified individual with a disability unless that accommodation would impose undue hardship. The ADA defines "a qualified individual with a disability" as an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that the individual holds or desires.

The Court, in reversing the Sixth Circuit Court of Appeals, unanimously held that one cannot measure an ADA disability based solely on an employee's inability to do certain tasks at work. Rather, the disability must prevent the employee from performing tasks central to daily life.

The case involved a Kentucky Toyota plant employee who developed carpal tunnel syndrome and shoulder tendinitis from performing repetitious manual tasks at work. The employer terminated the worker after she allegedly missed work on a regular basis and was placed on a no-work-of-any-kind restriction by physicians. The employee alleged that Toyota violated the ADA and the Kentucky Civil Rights Act by failing to reasonably accommodate her disability and by terminating her employment.

The lower court had previously held that for the employee to receive ADA protection, she need only show that her disability involved a "class" of manual activities affecting her ability to perform work tasks. In reversing, the Supreme Court held that the lower court erred in focusing on the employee's inability to perform manual tasks associated only with her job.

The Court stated that the central inquiry in identifying an ADA-protected disability is whether the claimant is unable to perform tasks central to most people's daily lives. Some tasks of "central importance to daily life" include tending to personal hygiene, household chores, bathing, and brushing one's teeth.

In the case of the Toyota plant worker, the Court noted that manual tasks unique to her particular job - "repetitive work with hands and arms extended at or above shoulder levels for extended periods of time" - are not necessarily an important part of daily life. Furthermore, the Toyota worker was able to tend to her personal hygiene, household chores, and other manual tasks of importance to her daily life.

The Court cautioned, however, that the analysis of whether a person has an ADA-protected disability must occur on a case-by-case basis. The Court noted that symptoms of carpal tunnel syndrome vary widely from person to person. The mere diagnosis of the syndrome is insufficient to conclude that the person has a disability. "Given these large potential differences in the severity and duration of the effects of carpal tunnel syndrome, an individual's carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA." Furthermore, some states provide employees protection greater than those under the ADA and those state laws must also be considered.

In considering the Court's decision in terms of employment practices, employers should note the following:

  • When confronted with an employee requesting accommodation under the ADA, a determination as to the existence of a disability must occur on a case-by-case basis. Employers must perform individualized analysis.
  • Remember that there are many other relevant factors to be considered beyond the employee's medical diagnosis in identifying an ADA-protected disability.
  • Because of the complexity of the legal issues, consider contacting legal counsel before making a determination as to whether an employee is entitled to ADA protection.

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