The U.S. Supreme Court Made It Harder for Employees to Claim Disability
On January 8, 2002, the United States Supreme Court issued a decision (Toyota v. Williams) that affects all employers with more than 15 employees. The ruling makes it more difficult for an employee to qualify as “disabled” under the Americans with Disabilities Act (ADA). This will reduce the number of times an employer is required to make a “reasonable accommodation” for the employee.
The ADA requires all employers with more than 15 employees to make accommodations for employees who can, despite a “disability,” perform the essential functions of the job that the individual holds or desires. However, “reasonable accommodation” is not required where it would impose an “undue hardship” upon the employer. A “disability” is primarily defined in the ADA as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual.”
The key question before the Supreme Court in Williams was: What is the proper standard for determining when an impairment substantially limits one or more of an individual’s major life activities for purposes of the ADA? In Williams, an assembly worker for Toyota sued that car manufacturer, claiming the company failed to provide her with a reasonable accommodation pursuant to the ADA though she was “disabled by carpel tunnel syndrome and other related impairments.” The employee said that her physical impairments limited her 1) manual tasks; and 2) working. More specifically, the employee claimed she could not do repetitive work with her hands and arms extended at or above shoulder levels for extended periods of time. She did admit, however, that she could still brush her teeth, wash her face, bathe, tend to her flower garden, fix breakfast, do laundry and pick up around the house.
The federal trial court judge dismissed the employee’s suit on the basis that these facts did not qualify the employee as “disabled” under the ADA. The employee appealed this decision to the 6th Circuit Court of Appeals. That court reversed the prior decision, and ruled that the facts qualified the employee as “disabled” under the ADA. Toyota asked the U.S. Supreme Court to review the case and it agreed to do that. The Court then overruled the 6th Circuit. In doing so, the Supreme Court established the standard by which employers must determine if their employees qualify as “disabled” under the ADA.
FIRST, the Supreme Court set a high standard for employees to reach before they qualify as ADA disabled: The employee must have a “permanent” or “long term” impairment “that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives.”
SECOND, the Supreme Court decided that an ADA “disability” cannot be decided by the medical diagnosis alone. This is because the effects of a particular medical diagnosis “vary widely from person to person.” Therefore, an “individualized assessment” of the “severity” and “duration” of the condition must be made.
THIRD, the Supreme Court reaffirmed that—where the major life activity under consideration is that of “working”—an ADA claimant must “show an inability to work in a broad range of jobs, rather than [just] a specific job.”
FOURTH, the Supreme Court rejected the assertion that an ADA claimant must show, when claiming she cannot perform “manual tasks,” that her disability involves a class of manual activities. Instead, the Court ruled that “[w]hen addressing the major life activity of performing manual tasks, 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.” This is because the Supreme Court believed that “the manual tasks unique to any particular job are not necessarily important parts of most people’s lives.” For example, the manual task at issue in Toyota v. Williams—repetitive work with hands and arms extended at or above shoulder levels for extended periods of time—were determined by the Supreme Court to be “not an important part of most people’s daily lives.” Instead, the Court believed that “household chores, bathing and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives” which should be part of the assessment of whether one is substantially limited in performing manual tasks.
Williams may be criticized for its failure to list for employers precisely what does constitute a “disability” under the ADA and what does not. Instead, the Supreme Court intentionally leaves the door open for ADA disabilities to be determined in a case-by-case manner.
What is clear, however, is that when an employee makes an ADA claim, the employer needs to “pry” into the employee’s personal life to determine if that person’s impairment substantially affects their “major life activities” at home, as well as in the broadly defined workplace.