Worker’s "Daily Life" Must Be Severely Affected to Be "Disabled" Under ADA
 
February 13, 2002
 

Understanding the Americans with Disabilities Act (ADA) recently became a little easier. The U.S. Supreme Court, in a case called Toyota Motor Manufacturing v. Williams, has ruled that to be protected by the ADA , employees or applicants must demonstrate that they have an impairment that prevents or severely restricts them from doing activities that are of central importance to most people's daily lives.

The ADA protects people with disabilities from being fired, demoted or otherwise discriminated against because of their disability, and requires employers to "reasonably accommodate" employees or applicants with disabilities, to enable them to perform their jobs. The ADA also prohibits discrimination against people who are regarded as having a disability or have a record of a disability. The question at the center of many workplace concerns under the ADA is what types of impairments qualify as "disabilities."

In the ADA, Congress defined "disability" to mean a "physical or mental impairment" that "substantially limits" one or more "major life activities" of the person with the impairment. Since the law was enacted in 1990, this broad definition of "disability" has bedeviled well-intentioned employers trying to comply with their legal obligations and has given rise to thousands of lawsuits and workplace disputes.

For example, Congress did not make clear whether someone with an impairment correctable through measures such as prosthetic limbs, medication or contact lenses, is still considered to have a "disability," since, without those corrective measures, the individual may have difficulty performing the major activities of life. Nor did Congress provide guidelines to determine when an impairment would be "substantially" limiting enough to constitute a disability.

Beginning in 1999, the Supreme Court began to narrow the broad language of the ADA by concluding that corrective measures should be considered when determining whether a person has a legal "disability." Then, in the Williams case, the Supreme Court narrowed the definition of "disability" even further.

In Williams, an assembly line worker who had been diagnosed with carpal tunnel syndrome and related impairments sued Toyota, claiming it failed to provide her with an accommodation she needed to continue working. The worker claimed that because of her impairment, she was unable to perform certain repetitive tasks that were part of her job description. She sued Toyota for its alleged refusal to change her job duties - that is, to provide her a "reasonable accommodation" under the ADA.

In the case on appeal, the lower federal court had ruled that the worker could demonstrate she was "disabled" under the ADA by showing that, due to her ailments, she was unable to perform the tasks associated with a class of manual activities related to her job duties - in her case, certain types of manual assembly line jobs. In reaching its decision, the lower federal court focused on the worker's ability to perform manual tasks relating to her job, but disregarded evidence that she could carry out personal and household chores and tend to her own personal needs.

The Supreme Court, however, reversed the lower federal court and ruled in favor of Toyota. The High Court found that the worker had, at most, demonstrated that she was unable to perform a limited class of manual tasks and had not shown that her impairments prevented her or restricted her from performing activities of central importance to daily life, such as walking, seeing and hearing. The Court concluded that, to be viewed as "substantially limited" in "major life activities" under the ADA, 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 Williams case substantially limits the definition of disability and may lead to a further decline in the number of lawsuits filed under the ADA. However, the Supreme Court changed the focus of the disability inquiry from an examination of the worker's ability to perform the essential functions of a job to a look at whether the person can perform basic daily tasks outside of work. This focus on tasks outside of work may hamper employers' ability to obtain the information necessary to make the disability determination. Employers should work with their employment counsel to determine ways to obtain the information necessary to make the "disability" determination under Williams. Moreover, employers should not rely on the Williams ruling to become less attentive to ADA concerns in the workplace. When faced with an employee who requests a problematic accommodation based on a dubious disability, management and counsel should engage in the interactive process and attempt to identify potential low-cost accommodations before concluding an employee is not disabled.

For more information, contact Eric Gabrielle at 888-688-8500 or via e-mail at egabriel@hklaw.com.