U.S. Supreme Court Narrows Reach of Disability Law
Mar 1, 2002
In a ruling that cheered business groups and disappointed disability rights advocates, a unanimous Supreme Court narrowed the scope of the Americans With Disabilities Act ("ADA") in January, ruling that an impairment must have a substantial effect on a person's daily life to qualify as a disability under the law. The landmark 1990 law was intended to open opportunities to Americans with physical or mental disabilities by guaranteeing equal treatment on the job and elsewhere for people whose disabilities substantially limit? their ability to perform what the law calls "major life activities," such as caring for oneself.
Plaintiff Ella Williams claimed to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments. Her restrictions meant Williams could perform some but not all her assigned duties on the factory floor. She asked for reassignment and sued under the ADA when Toyota refused. A federal district judge dismissed Williams' suit in 1997, but a federal appeals court in Cincinnati upheld her claim, ruling that her inability to perform manual tasks on the assembly line constituted a disability under the ADA. Toyota appealed to the Supreme Court.
The decision, the Supreme Court's first major ruling involving carpal tunnel injuries, continued the justices' pattern of narrowly interpreting the ADA. The opinion helps clarify the meaning of disability and key ADA terminology including substantially limit, and major life activity.
Under a clause in the ADA, the provision states in part: the term disability means, with respect to an individual … a physical or mental impairment that substantially limits one or more of the major life activities of such individual. In determining whether or not a person is disabled, Justice Sandra Day O'Conner 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.
O'Connor said the law clearly precluded impairments that interfere in only a minor way with performing manual tasks. The manual tasks unique to any particular job are not necessarily important parts of most people's lives, she said. Moreover, merely having an impairment does not make one disabled for purposes of the ADA. The Court noted that in passing the ADA, Congress referred to 43 million Americans with 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.
Moreover, disability cannot be assessed by looking only at someone's fitness to work. "It is insufficient for individuals attempting to prove disability status to merely submit evidence of a medical disability," O'Connor wrote. 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. To be substantially limited in performing manual tasks (and covered by the ADA), O'Connor wrote, an individual must not only have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives but also an impairment whose impact is permanent or long-term.
Whether someone is disabled must depend on the ease with which they perform quot;activities that are of central importance to most people's daily lives." Into that category the Court put walking, seeing, household chores, bathing, brushing one's teeth and hearing. "Repetitive work with hands and arms extended at or above shoulder levels for extended periods is not an important part of most people's daily lives," O'Connor wrote. Conditions that only prevent a worker from performing a specific job-related task are not legal disabilities. Claimants need to demonstrate that the impairment limits a major life activity.
The Supreme Court's ruling does not mean that anyone with carpal tunnel syndrome or similar partial disabilities is automatically excluded from protection by the ADA. But it probably will make such claims harder to prove, since the Court makes clear that disability must affect a range of manual tasks or duties. The fact that the ADA defines "disability" "with respect to an individual," however, makes clear that Congress intended the existence of a disability to be determined on 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.