The definition of "disability" has been a complicated one, particularly since the term is used differently by and among state and federal agencies. This difficulty in finding consensus is complicated by the fact that the terms used to define disability also have multiple agency interpretations. Courts must continually address questions such as what is a major life activity and what is a substantial limitation. Caselaw has arisen regarding the differing requirements for the determination of disability as they exist between the Social Security Disability Act, California's Retirement Plan, and the Americans with Disabilities Act. In this case the different programs' definition of disability required different outcomes.
Broussard
The Ninth Circuit in the case of Broussard v. University of California, at Berkeley, 1999 Daily Journal D.A.R. 9865 (No. 97-17389), United States Court of Appeals, Ninth Circuit 9/20/99 held that an employee was not "substantially limited" in a major life activity after being diagnosed with carpal tunnel syndrome, and could not be deemed as disabled under the Americans with Disabilities Act (ADA).
Broussard had held a position caring for lab animals that couldn't be accomplished when she developed carpal tunnel syndrome. She was placed in a temporary position until it could be determined that she couldn't perform the job permanently. A similar position existed but Broussard lacked the necessary qualifications. Broussard was then terminated.
Even though the employee was terminated from her position, and was awarded benefits as a disabled employee under the University of California Retirement Plan, she was denied benefits under the Social Security Act. After being terminated, Broussard sued the University contending that it had violated the ADA after it found that she was incapable of performing her responsibilities. The trial court had granted a summary judgment in favor of the University. The United States Court of Appeals affirmed. The court stated that under the ADA, disability is a "physical or mental impairment that substantially limits one or more of the major life activities".
The court held that the applicant failed to show that she faced significant restrictions in her ability to meet the needs of other jobs even if it was found that she was unable to continue in her position as an animal technician in the office of laboratory animal care. She was not substantially limited in the major life activity of working merely because she was unable to perform a particular, specialized job, and the court held that she could not therefore be deemed to be covered under the ADA as she failed to show that she faced significant restrictions in her ability to meet the needs of other jobs. As she was not covered under the ADA all other issues raised were deemed to be irrelevant.
Related Claims
It is important to understand that the requirements for Long Term Disability, Social Security Disability and the ADA (Americans with Disabilities Act) are different. In many instances an individual may qualify for benefits under one and not under another. The inter-relationship of the three should best be determined after a consultation with an experienced legal practitioner in the appropriate area of law.