The United States Supreme Court has again made it harder for people to bring claims under the Americans with Disabilities Act. In a decision likely to have a significant impact on assessment of future ADA claims, the United States Supreme Court has ruled that for a worker to be deemed “substantially limited” in performing manual tasks, that person must have a permanent or long-term impairment “that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives.” Toyota Motor Manufacturing, Kentucky, Inc. vs. Williams, — U.S. —, S.Ct. —, 2002 WL 15402 (January 8, 2002) involved the claims of an assembly line worker with carpal tunnel syndrome who was unable to perform some of the tasks associated with certain types of manual labor within her job description. Dissatisfied with management’s response to her concerns about the physical requirements of her position, the worker sued Toyota alleging it had violated the ADA by refusing to accommodate her disability.
The trial court in Kentucky threw out the worker’s suit, saying her impairment had not substantially limited any of her major life activities within the meaning of the statute and thus was not the sort of “disability” the ADA requires employ-en to accommodate. The court also ruled that the worker had failed to present evidence that she had any record of a “substantially limiting impairment,” or that Toyota regarded her as having such an impairment. Either one of those circumstances, if established, would trigger ADA protections for the employee.
On appeal, the Sixth Circuit Court of Appeals reversed, saying that the worker’s impairments did substantially limit her in a major life activity it designated as “performing manual tasks.” That court disregarded evidence that the worker was able to tend to her personal hygiene and household chores. It ruled in the worker’s favor, saying that in fact she was disabled within the meaning of the ADA.
The United States Supreme Court reversed, concluding that the Sixth Circuit Court of Appeals was incorrect to limit its analysis to those manual tasks associated with the worker’s position on the assembly line. Focusing on more than just a person’s work life, the Court ruled that to be deemed “substantially limited” in performing manual tasks, the person must have a permanent or long-term impairment “that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives.”
Another aspect of the Toyota decision that should prove comforting to employers — if not to employees — is its treatment of how claimants must prove disability status. The Court reemphasized that the ADA requires employees claiming protection to prove disability by offering evidence that the extent of the limitation caused by their impairment is substantial in terms of their own experience with a disease or disorder. This means that an employer’s determination of whether an individual has a disability should not focus or be based simply on the name or diagnosis of the employee’s impairment, but instead, should be based on the effect of that impairment on the life of that person. (Examples of diagnoses invoking this sort of determination by the Court include that of an employee with HIV infection, and another with monocular vision.)
Ultimately, the Toyota decision may come to be viewed as another common sense point in evolving conceptions of impairment under the ADA, along the lines of the Court’s 1999 decisions which held that the impairments of people seeking protection under the ADA must be evaluated in their corrected states. Even with the Supreme Court doing its part to narrow the reach of the ADA, employers must still recognize the complexity of the issues presented, and the risk of liability whenever a request for accommodation arises. Counsel experienced in ADA matters can help you avoid an undesired risk or result.