Labor and Employment

SUPREME COURT DEFINES A "DEMANDING STANDARD FOR QUALIFYING AS DISABLED" UNDER THE ADA


Determining whether an employee is "disabled" has often been a problem for employers. Such a determination is critical, however, to determining whether the employee is entitled to special treatment under the law.

In the recently decided case of Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, the United States Supreme Court interpreted the meaning of "disability," which is defined in the Americans with Disabilities Act (the ADA), as follows:

a physical or mental impairment that substantially limits one or more of the major life activities of such individual;

a record of such an impairment; or

being regarded as having such an impairment.

The Court indicated that whether someone can be classified as "disabled" under the above definition depends upon how his or her major life activities are affected, and not upon whether he or she can perform a certain job.

The employee, Ella Williams, worked at Toyota’s Georgetown, Kentucky plant. She had originally been assigned to the engine fabrication line, where she was required to use pneumatic tools. Use of these tools resulted in her contracting carpal tunnel syndrome and tendonitis. Two years after diagnosis of her condition, she was assigned to modified duty, so as not to exacerbate her condition.

Eventually, the employee became dissatisfied with Toyota’s efforts to accommodate her disability, and filed suit claiming violations of the ADA.

The Supreme Court first indicated that to qualify under the ADA for a "reasonable accommodation," a claimant must show a physical or mental impairment which substantially limits a major life activity (for example, walking, seeing, hearing, and performing manual tasks). The key, according to the Court, was the word "substantially." Thus, "to be substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives. The impairment’s impact must also be permanent or long-term."

Applying these holdings to the facts before it, the Supreme Court concluded that merely because the employee had carpal tunnel syndrome did not automatically mean that she "qualified" under the ADA for a "reasonable accommodation," since the symptoms of carpal tunnel syndrome vary widely from person to person. The Court held that it was in error to focus on the employee’s inability to perform a certain job. Rather, the real issue was whether the carpal tunnel syndrome prevented the employee from performing manual tasks. As the Court noted, "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 particular job." Since the employee could perform some manual tasks, she was not "qualified" under the ADA for a "reasonable accommodation."

On the surface, the case would appear to be a victory for employers. Just because an employee cannot perform the duties of a job does not mean that a "reasonable accommodation" must be made. Rather, the extent of the disability must be examined to determine if the employee is "substantially limited in performing manual tasks." In other words, does the employee have a permanent disability which restricts major life activities, such as walking, seeing, hearing, or performing manual tasks? Unfortunately, making this determination on a case-by-case basis could be time-consuming and complicated.

February 2002