Supreme Court Narrows Definition of Disability for ADA

The U.S. Supreme Court has spoken, and it's not looking good for workers who hoped to claim - like a Toyota worker - that their work-related musculoskeletal injuries grant them job protections under the Americans with Disabilities Act (ADA).

The U.S. Supreme Court has spoken, and it''s not looking good for workers who hoped to claim - like a Toyota worker - that their work-related musculoskeletal injuries grant them job protections under the Americans with Disabilities Act (ADA).

In a ruling handed down yesterday that narrows the definition of a "disability" as it applies to the ADA, Justice Sandra Day O''Connor wrote, "The central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people''s daily lives, not whether the claimant is unable to perform the tasks associated with her specific job.''''

Ella Williams, a former employee of Toyota Motor Corp.''s Georgetown, Ky., facility, is not covered by the ADA, ruled the court, because she can still perform many tasks at home - such as cooking, cleaning and gardening - as well as many work-related tasks. Just not her, specific, work-related tasks.

The Supreme Court reversed a decision in Williams'' favor handed down by the Cincinnati-based 6th U.S. Circuit Court of Appeals and returned the case to that court for reconsideration.

Williams claimed that within months of starting work at Toyota, she began having problems with her shoulders, arms and hands. Claiming she suffered from carpal tunnel syndrome, Williams filed a workers'' compensation claim and sued under the ADA.

A doctor prescribed light duty and she was given a job inspecting paint. Williams had no problems performing that job, but when Toyota changed the job duties for inspectors, she claimed she was unable to perform her new job tasks. At that point, she was either fired or resigned from the company.

She sued, and the case made it to the court of appeals, which found in Williams'' favor. Toyota appealed the decision, and the Supreme Court agreed to hear the case.

The ADA bans job discrimination against disabled workers and requires employers to offer them reasonable accommodations. According to the ruling by the Supreme Court, the definition of disabled cannot be measured on the ability to do certain work tasks. It also depends on workers'' abilities to perform tasks such as walking and seeing, "activities that are of central importance to most people''s daily lives," the Supreme Court ruled.

"The manual tasks unique to any particular job are not necessarily important parts of most people''s lives. As a result, occupation-specific tasks may have only limited relevance to the manual task inquiry," wrote O''Connor in her decision. Therefore, she added, the court of appeals should not have considered Williams'' inability to do manual work in her specialized assembly line job "as sufficient proof that she was substantially limited in performing manual tasks."

The Supreme Court noted that when Congress enacted the ADA in 1990, it found that approximately 43 million Americans have one or more physical or mental disabilities. "If Congress intended everyone with a physical impairment that precluded the performance of some isolated, unimportant or particularly difficult manual task to qualify as disabled, the number of disabled Americans would surely have been much higher," noted the court.

Business groups, such as those represented by the U.S. Chamber of Commerce, were pleased with the decision.

"The Court understood that the ADA was not meant to create a loophole for people with routine limitations or minor injuries, but was intended for people with significant limitations," said Stephen Bokat, Chamber general counsel and executive vice president of the National Chamber Litigation Center, adding that the decision "came down on the side of a reasonable definition of disability."

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," continued Bokat.

The American Association of People with Disabilities (AAPD) criticized the decision, with President and CEO Andrew J. Imparato calling the ruling "another in a series of decisions where the Supreme Court has inappropriately restricted the scope of who is disabled enough to have civil rights protections under the ADA."

These cases are about whether victims of disability discrimination get their day in court, he noted. "Ignoring Congress''s explicit use of an inclusive definition of ''disability'' in the ADA, the Supreme Court ... has gone out off its way to narrow the definition of ''disability'' and thereby limit access to the courts for victims of discrimination."

For more information on this case, see the related article "Supreme Court Examines Work-related ADA Case" and make sure you read the feature article written by Washington editor James Nash in the upcoming February issue of Occupational Hazards magazine.

by Sandy Smith ([email protected])

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