The U.S. Supreme Court recently handed down a resolute victory for management in defining and limiting the scope of the Americans with Disabilities Act. In Toyota Motor Manufacturing, Kentucky v. Williams, a unanimous Supreme Court held that although an employee may be limited in performing certain tasks related to a job, this alone did not entitle her to protection under the Americans with Disabilities Act (ADA). Rather, the Court explained, to qualify for protection under the ADA employees must show that they suffer from a physical or mental impairment that renders them "unable to perform the variety of tasks central to most people’s daily lives." The Court’s decision should limit an employee’s ability to claim that a relatively minor condition or an impairment that does not significantly impact a range of activities qualifies them as "disabled" under the ADA.
As most employers are aware, the ADA requires an employer to provide "reasonable accommodation" to an "otherwise qualified individual with a disability." The ADA defines "disability" in relevant part as a physical or mental impairment "that substantially limits one or more . . . major life activities."
The employee in Toyota was an assembly worker who suffered from carpal tunnel syndrome and tendinitis. She was assigned to a light-duty "paint inspection group" and worked for several years performing a limited number of tasks without incident. The company subsequently decided to change the job description for employees in the group, requiring all employees to perform a variety of tasks, some of which involved manual tasks (as opposed to mere visual inspection). When the employee’s medical condition re-emerged, the employee asked that she be allowed to limit her duties to the original functions of her job (i.e., visual inspection) and not be required to perform manual tasks. The parties differed on what happened next. The employee claimed that Toyota refused to grant her request, exacerbating her medical condition. Toyota claimed that the employee began missing work on a regular basis. In any event, the employee was terminated shortly thereafter for a poor attendance record.
The employee subsequently sued her employer claiming that she was "disabled" within the meaning of the ADA, and that Toyota violated the ADA by failing to accommodate her request for modified duties. The trial court ruled in favor of Toyota. The appeals court, however, reversed the lower court’s judgment, ruling that because the employee’s ailment "prevent[ed] her from doing the tasks associated with certain types of manual assembly line jobs" she was properly classified as disabled under the ADA and could proceed with her claim. In arriving at its conclusion, the appeals court ignored evidence that the employee’s medical condition did not limit her from tending to her personal hygiene or carrying out household chores. The Supreme Court granted review of the case to clarify the standard as to when an individual’s limitation in performing certain manual tasks renders him or her "disabled" under the ADA.
The Supreme Court reversed the appeals court and remanded the case for further proceedings, holding that the employee’s medical limitations were not sufficient to render her "disabled" under the ADA. As the Court observed, "Merely having a disability does not make one disabled for purposes of the ADA. [An employee] also need[s] to demonstrate that the impairment limits a major life activity . . . [which] includes ‘walking, seeing, hearing,’ and ‘performing manual tasks.’" The Court went on to explain that in assessing whether an employee was substantially limited in performing manual tasks, the law does not look solely to tasks related to employment (e.g., lifting or repetitive motion) but rather to the range of manual tasks that are "central to most people’s daily lives, not . . . [those] associated with her specific job." The Court noted that evidence that the employee could engage in household activities, personal chores, gardening and personal hygiene indicated that she was not "substantially limited in performing manual tasks."
The Supreme Court’s decision clearly limits the reach of the ADA and should provide employers with a strong defense that employees suffering from relatively minor ailments are not "disabled" under federal law. Employers should note, however, that the Supreme Court’s ruling is not binding on state court interpretations of analogous state laws. In a number of states, state equal employment laws have been interpreted to afford employees greater protection than their federal law counterpart.
It is also important to note that the Supreme Court’s decision did not go so far as to say that carpal tunnel syndrome, or similar medical restrictions, could never be a covered disability under the ADA, only that the employee in Toyota was not sufficiently limited by her own medical condition. Indeed, the Court expressly stated that in certain instances, depending on its severity and duration, carpal tunnel syndrome might render an individual "disabled" within the meaning of the ADA.
While Toyota is good news for employers, determinations as to whether a particular employee will be held to be disabled under ADA will continue to turn on the specific facts of each case. Accordingly, employers facing questions concerning employees’ status under the ADA, or other employment disability issues, are advised to consult counsel.