Supreme Court Narrows Application of ADA

U.S. Supreme Court Narrows Application of the Americans With Disabilities Act

NEWS ALERT On January 8, the U.S. Supreme Court issued a decision making it more difficult for employees to pursue disability discrimination claims under the Americans with Disabilities Act. The Court's unanimous decision in the case of Toyota Motor Manufacturing Kentucky v Williams limits the definition of a covered disability under the ADA. The Court's decision also signals that it will interpret the ADA's provisions narrowly. Ella Williams was employed by Toyota in its automobile assembly operations. She worked on a team in Toyota's quality control inspection. Team members performed four types of tasks, and at first were assigned to performed only a portion of these tasks. During the latter part of Williams' employment, Toyota decided that all team members needed to rotate through each of the quality control inspection tasks. Ms. Williams, who had a history of carpal tunnel syndrome, asked Toyota to accommodate her by assigning her to the two tasks that she had performed in the past. She claimed that Toyota refused her request. In any event, she continued to work on this rotation but started missing work on a regular basis. Toyota thereafter terminated her employment for poor attendance. Ms. Williams then filed a lawsuit under the ADA, asserting that she was a qualified individual with a disability because she had carpal tunnel syndrome which substantially affected her in the performance of several major life activities, including working, performing manual tasks, and lifting. She also claimed that Toyota failed to reasonably accommodate her disability. Is Carpal Tunnel Syndrome a Covered Disability under the ADA? Many employers have closely followed this case because it provided the courts with the opportunity to rule whether carpal tunnel syndrome constituted a protected disability. The Supreme Court declined to issue such a bright line ruling. Instead, it stated that whether someone has a protected disability must be determined on a case-by-case basis. It then closely analyzed the ADA's definition of a disability and applied that definition to Ms. Williams' testimony concerning her limitations from her carpal tunnel syndrome. In doing so, the Court focused on whether she could show that her impairment substantially limited her major life activity of performing manual tasks. Does a Person Have to be Limited in More Than Just Their Job? The U.S. Court of Appeals for the Sixth Circuit had ruled that Ms. Williams was substantially limited in performing manual tasks because she had shown that she was restricted in activities associated with the performance of her assembly line job. That job required her to grip tools and perform repetitive work with her hands and arms extended at or above shoulder levels for extended periods of time. Ms. Williams' testified that she could not perform these activities. According to the Supreme Court, the lower court of appeals incorrectly focused on Ms. Williams' limitations in performing her job. The Supreme Court ruled that a person claiming that their impairment substantially limits the performance of manual tasks must show that the disability affects life activities that are of central importance to most people's daily lives. As a result, to demonstrate a covered disability a person would have to show that an impairment prevented or severely restricted them from doing a variety of activities, not just work related activities. Ms. Williams had testified that she could still perform two of the four tasks of her job, and that she could brush her teeth, wash her face, bathe, tend he flower garden, prepare food, and pick up around the house. The Supreme Court therefore ruled that she had not demonstrated that she was disabled under the ADA. In addition, the Supreme Court ruled that in proving disability status a person must submit more than just evidence of medical diagnosis of impairment. A person must also offer evidence showing how that impairment limits them in the performance of a major life activity. If the person asserts that the impairment affects their ability to perform manual tasks, the person must show that it affects in more than just their job. The Supreme Court's decision does not reduce an employer's obligation to determine the extent of an employee's disability when assessing whether a reasonable accommodation needs to be provided. In assessing their obligations under the ADA, Employers will still want to probe into the nature the employee's impairment, and how it affects the employee in the performance of the job and in other life activities. Even so, Employers may keep in mind that the decision further restricts a person's ability to demonstrate that they have a covered disability under the ADA that requires such an accommodation. This News Alert was prepared by David R. Deromedi. Mr. Deromedi practices out of Dickinson Wright's Detroit office and specializes in disability discrimination litigation and counseling. If you would like further information about this development or any other issue of employment or labor law, please feel free to contact him or any one of the members of our employment and labor law group (see link below).
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