Supreme Court Limits Scope of Americans With Disabilities Act

By John Lowe

Yesterday the U.S. Supreme Court issued a major decision that considerably limits the application of the Americans With Disabilities Act of 1990 (ADA). In a somewhat surprising unanimous decision, the Court reversed the lower court's interpretation of the definition of what constitutes a "disability," thereby limiting the number of individuals who are protected by the ADA. Although the quick interpretations of Supreme Court cases that appear in popular media are at times misleading, we believe the business groups who have applauded this decision in the papers this morning are correct in their assessment that this is a major victory for businesses across the country.

In Toyota Motor Manufacturing, Kentucky, Inc. v. Ella Williams, Ms. Williams claimed to be disabled because of carpel tunnel syndrome, myotendinitis, and thoracic outlet compression, and she brought suit against Toyota for failing to provide her with a reasonable accommodation of her disability. Toyota argued that Ms. Williams' impairments did not entitle her to protection under the ADA because they did not constitute a "disability" under the Act because she was not "substantially limited" in "one or more...major life activities." 42 U.S.C. § 12102(2)(A).

The District Court (trial court) granted summary judgment to Toyota, finding that Ms. Williams' impairments did not constitute a disability. The Court of Appeals for the Sixth Circuit (which covers Ohio) reversed that decision, finding that the impairments substantially limited Ms. Williams' major life activity "of performing manual tasks" and therefore granted partial summary judgment to her. The Court of Appeals disregarded evidence that Ms. Williams could "tend to her personal hygiene and carry out personal or household chores" because it determined that such evidence "does not affect a determination that her impairment substantially limited her ability to perform the range of manual tasks associated with an assembly line job."

The Supreme Court concluded that the Court of Appeals did not apply the proper test in making its determination because it analyzed only a limited class of manual tasks relating to her ability to perform her job for Toyota. The Supreme Court held that the correct question for determining whether Ms. Williams suffered from a substantial limitation in a major life activity of performing manual tasks, a category it found to include such basic abilities as walking, seeing and hearing, was whether the tasks are of "central importance in most people's daily lives." In reaching this determination, the Court noted that when Congress enacted the ADA in 1990 it found some "43,000,000 Americans have one or more physical or mental disabilities" and if Congress intended "everyone with a physical impairment that precluded the performance of some isolated, unimportant, or particularly difficult manual task to qualify as disabled, the number of disabled Americans would surely have been much higher." The Court also noted that in order to qualify as a disability, an impairment must "be permanent or long-term." The Court stated:

When addressing the major life activity of performing manual tasks, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job...The manual tasks you need to do any particular job are not necessarily important parts of most people's lives. As a result, occupation-specific tasks may have only limited relevance to the manual task inquiry.

The Court noted that in this case, Ms. Williams' inability to complete "repetitive work with hands and arms extended at or above shoulder levels for extended periods of time" is not an "important part of most people's lives." Therefore, the Supreme Court ruled that the Court of Appeals erred in determining that Ms. Williams' inability to do the manual work in her assembly line job was sufficient proof that she was "substantially limited in performing manual tasks." The Supreme Court remanded the case, instructing the lower courts to pay specific attention to whether Ms. Williams can "tend to her personal hygiene and carry out personal or household chores" such as bathing, brushing ones teeth, etc.

Conclusion

While lower court interpretations of this ruling in the next year or two will determine its true breadth, the Supreme Court has significantly curtailed the scope of individuals covered by the ADA. As a result, companies may be able to limit the number of employees to whom they provide accommodation.

Upcoming Events

We will discuss this case, other ADA issues, and four other specific employment law topics at our Seminar on February 11, 2002. If you have not signed up for the Seminar, please feel free to do so by clicking here (Adobe Acrobat PDF - requires the free Acrobat Reader).