United States: Employers Get Favorable Ruling in ADA Case

In a ruling earlier this year, the United States Supreme Court clarified the question of what type of impairment qualifies as a disability under the Americans with Disabilities Act (ADA) by requiring that the claimant show that his or her impairment renders the claimant "unable to perform the variety of tasks central to most people’s daily lives", not merely that the claimant is "unable to perform the tasks associated with [their] specific job." Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, No. 00-1089, 2002 U.S. LEXIS 400, 534 U.S. 184 (2002). The Court was asked to determine whether impairments substantially limited the major life activity of performing manual tasks, thereby requiring that an employer provide reasonable accommodations under the ADA to the employee.

Williams was an assembly line worker in the Toyota manufacturing plant and alleged that carpal tunnel syndrom prevented her from working. She argued that she was disabled under the ADA and was prevented from performing her specific assembly line job. The Court did not dispute Williams’ medical conditions as constituting physical impairments. Rather, the Court felt that the relevant inquiry was whether Williams could perform the variety of tasks "central to most people’s daily lives, not whether she was unable to perform tasks associated with her specific job." The Court required that the impact of the impairment be permanent or long term.

In reviewing the history behind the enactment of the ADA, Justice O’Conner noted that Congress estimated that "some 43,000,000 Americans have one or more physical or mental disabilities." Had Congress intended the ADA to apply to anyone with a physical impairment affecting performance of a particular manual job task, the estimate would have been significantly higher.

The Court required that an individual analysis be used to determine the effect of an impairment on a claimant’s ability to perform "the variety of tasks central to most people’s daily lives." When a major life activity under consideration by the Court is that of working, the Court felt that plaintiffs should allege they are unable to work in a broad class of jobs rather than unable to perform certain specific manual tasks. Since plaintiff Williams was able to tend to her personal hygiene and perform various personal and household chores, the Court felt that she was unable to prove a disability under the ADA since the tasks she was able to complete were of "central importance to people’s daily lives."

This ruling is viewed as imposing a limitation on an employee’s ability to prove an ADA disability by requiring that the disability "have a substantial affect on a person’s daily life." Commentators have remarked that this could reduce the number of marginal cases filed against employers but it was not likely to encourage employers to resist making accommodations for employees who have impairments that actually affect their work.

County employers are encouraged to consider the necessary accommodations for disabled employees. However, this decision does allow counties to review the nature of the disability and be sure that the limitation alleged is truly a limitation on an individual’s daily life.