On January 8th, 2002, the U.S. Supreme Court ruled in favor of Toyota when it decided that former employee Ella Williams did not qualify as “disabled” under the Americans With Disabilities Act (ADA). A few have since speculated that the Court’s decision dealt a blow to occupational ergonomics, but a close look at the ruling shows that is not true, and may in fact have a positive influence with respect to ergonomics in the workplace.
The only link to occupational ergonomics in the case was that Williams purportedly suffered from Carpal Tunnel Syndrome (CTS) and related ailments that resulted from her duties as an assembly worker in a Toyota Manufacturing plant. Whether or not her condition was caused by her work was not at issue, and it appears that the Court accepted her impairments and consequent physical limitations as fact. That is, Toyota did not ask the Court to decide on an issue of ergonomics; they did ask the Court whether her impairments qualified Williams as “disabled” under the ADA.
In essence, the Court responded that an impairment, regardless of its name or medical diagnosis, could be classified as a disability only if it limits a person’s ability to perform “major life activities.” The Court suggested that activities such as household chores, bathing, and brushing one’s teeth, for example, are of central importance to most people’s daily lives. Performing a certain set of tasks on an assembly line, on the other hand, is not necessarily important to the daily lives of the broader American population. Presumably, had Williams impairments restricted her from household chores, bathing, etc., the Court would have defined her as disabled under the ADA.
Labor activists have responded that one’s work life is a “major life activity” for most people, and that impairments that limit one’s ability to work should be covered under the disability definition. The difference between this perspective and the Court’s opinion seems to be one of an individual vs. population comparison. Some activists feel that the test should be whether an individual is disabled with respect to his or her own daily life, whereas the Court states that the test must be against the entire population. Williams couldn’t do the specific tasks in her specific job, but she could still perform what most people do in their daily life activities. So, while the Court clearly stated that each individual must be evaluated on a case-by-case basis, the evaluation must compare him or her to the population, not only to themselves, in the determination of disability.
The Court also said an impairment must be long-term to qualify as a disability Since the severity of impairments such as CTS may change over time, or may even heal completely, a mere diagnosis is not enough to prove disability.
Prior to this decision, business was concerned that if an employee had any impairment that restricted any work activities, the employee might have the makings of an ADA case. The U.S. Chamber of Commerce hailed the decision saying “Expanding the ADA from covering workers with disabilities to include workers who cannot perform a particular job function would have exploded the cost of doing business, and dramatically increased all employers’ risk for lawsuits from disgruntled workers.”
The American Association of People with Disabilities (AAPD) criticized the decision. “These cases are about whether victims of disability discrimination get their day in court. Ignoring Congress’s explicit use of an inclusive definition of ‘disability’ in the ADA, the Supreme Court today and in earlier decisions has gone out off its way to narrow the definition of ‘disability’ and thereby limit access to the courts for victims of discrimination.”
Some experts believe the ruling will have less impact than most observers expect. For instance, pointing to the differences between state and federal workplace laws, Fred Main, Senior Vice President of the California Chamber of Commerce, believes the Supreme Court decision will have little effect in his state. “As in many issues of employment law, California’s courts are a more favorable venue than the federal courts for workers,” he said. Claudia Senter, a staff attorney at the Legal Aid Society’s Employment Law Center in San Francisco notes that California law only a requires a “limitation” to a “life activity,” as opposed to the stricter ADA language “substantially limits” and “major life activities.” Therefore, California and other states may have a broader definition of disability in their state laws, and employees with disability claims will likely sue in state rather than federal courts as a result.
Williams vs. Toyota was not a case questioning ergonomics, nor was it a case questioning Carpal Tunnel Syndrome or it’s potential relationship to work. In fact, the impairments and potential work-relatedness associated with the disorder appear to have been taken for granted by the Court. The case really focused on the question of who is disabled and who is not, within the confines of the Americans With Disabilities Act. With this decision the Federal Court has narrowed and clarified that definition, making it more exclusive than many previously interpreted. State laws may have more inclusive definitions, and if so, expect to see certain disability cases fought in state courts, rather than federal.