The Supreme Court of the United States has rendered an opinion that sets important precedence for the interpretation of the Americans with Disabilities Act (ADA). The decision helps clarify the meaning of “disability” and key ADA terminology including “substantially limit,” and “major life activity.” In a nutshell, the Court decided in favor of Toyata, and suggests that a disability must be evaluated on an individual, case-by-case basis; that a mere diagnosis of impairment is not sufficient evidence under the test of substantially limiting major life activities; that an impairment’s impact must be permanent or long-term; that manual tasks in question must be central to daily life; and that impairments that limit only work activities do not meet the definition of “disability” in the Act.
In Toyota v. Williams (No. 00-1089), Plaintiff Ella Williams, claiming to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, sued her former employer, Toyota, for failing to provide her with a reasonable accommodation as required by the ADA. A lower court had previously granted Toyota summary judgment, holding that Williams impairment did not qualify as a “disability” under the ADA because it had not “substantially limit[ed]” any “major life activit[y],” and that there was no evidence that she had had a record of a substantially limiting impairment or that Toyota had regarded her as having such an impairment.
The Sixth Circuit Court, who found that Williams’s impairments substantially limited her in the major life activity of performing manual tasks, reversed that decision. In order to demonstrate that she was so limited, according to that court, Williams had to show that her manual disability involved a “class” of manual activities affecting the ability to perform tasks at work. She satisfied this test, said that court, because her ailments prevented her from doing the tasks associated with certain types of manual jobs that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time. In reaching that conclusion, Sixth Circuit found that evidence that Williams could tend to her personal hygiene and carry out personal or household chores did not affect a determination that her impairments substantially limited her ability to perform the range of manual tasks associated with an assembly line job.
The unanimous Supreme Court decision, delivered January 8, 2002, by Justice O’Conner, holds that the Sixth Circuit did not apply the proper standard in determining that Williams was disabled under the ADA because it analyzed only a limited class of manual tasks and failed to ask whether her impairments prevented or restricted her from performing tasks that are of central importance to most people’s daily lives. The Court interpreted the word “substantially,” as used in “substantially limits” in the ADA, as suggesting “considerable” or “to a large degree,” and thus clearly precludes impairments that interfere in only a minor way with performing manual tasks. Further, because “major” means important, “major life activities” refers to those activities that are of central importance to daily life. Therefore, manual tasks in question must be central to daily life. To be substantially limited in the specific major life activity of performing manual tasks, therefore, 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.
The Court holds that it is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment. Instead, the ADA requires them to offer evidence that the extent of the limitation caused by their impairment in terms of their own experience is substantial. That the ADA defines “disability” “with respect to an individual,” makes clear that Congress intended the existence of a disability to be determined in a case-by-case manner. An individualized assessment of the effect of an impairment is particularly necessary when the impairment is something like carpal tunnel syndrome, in which symptoms vary widely from person to person.
The Court believes the Sixth Circuit erred in suggesting that in order to prove a substantial limitation in the major life activity of performing manual tasks, a plaintiff must show that her manual disability involves a “class” of manual activities, and that those activities affect the ability to perform tasks at work. The Sixth Circuit’s analysis erroneously focused on Williams’s inability to perform manual tasks associated only with her job. Rather, the central inquiry must be whether she is unable to perform the variety of tasks central to most people’s daily lives. Also without support is the Sixth Circuit’s assertion that the question whether an impairment constitutes a disability is to be answered only by analyzing the impairment’s effect in the workplace. That the Act’s “disability” definition applies not only to the portion of the ADA dealing with employment, but also to the other provisions dealing with public transportation and public accommodations, demonstrates that the definition is intended to cover individuals with disabling impairments regardless of whether they have any connection to a workplace. Moreover, because the manual tasks unique to any particular job are not necessarily important parts of most people’s lives, occupation-specific tasks may have only limited relevance to the manual task inquiry. In this case, repetitive work with hands and arms extended at or above shoulder levels for extended periods, the manual task on which the Sixth Circuit relied, is not an important part of most people’s daily lives. Household chores, bathing, and brushing one’s teeth, in contrast, are among the types of manual tasks of central importance to people’s daily lives, so the Sixth Circuit should not have disregarded Williams’s ability to do these activities.
Reference: Legal Information Institute, http://supct.law.cornell.edu/supct/html/00-1089.ZS.html