In Toyota Motor Mfg., Ky., Inc. v. Williams, No. 00-1089 (Jan. 8, 2002), the Supreme Court held that the appropriate standard for judging whether an individual is disabled under the Americans with Disabilities Act (ADA) must consider whether the impairment prevents or restricts the individual from performing tasks of central importance to most people's daily lives.
The ADA protects employees from being discriminated against because of a disability and requires employers to reasonably accommodate limitations. However, an employee must establish he or she has a "physical or mental impairment that substantially limits" one or more "major life activities," which include caring for one's self, performing manual tasks, walking, seeing, hearing, breathing and working.
The plaintiff in Williams suffered from carpal tunnel syndrome, which resulted in permanent physical limitations. Williams' job required her to rotate through four positions, two of which conflicted with her limitations. She claimed she asked to be excused from rotations that conflicted with her restrictions, but her request was denied. A short time later, she was terminated for attendance reasons.
Williams sued Toyota, claiming discrimination under the ADA. The trial court dismissed her claim on the grounds that she did not have sufficient evidence to demonstrate that her impairment substantially limited her in the major life activities of lifting, working or performing manual tasks.
Williams appealed to the Sixth Circuit Court of Appeals, which reversed the trial court, finding that she was disabled because she had proven her condition prevented her from doing manual tasks associated with certain classes of jobs.
Then, the U.S. Supreme Court rejected the Sixth Circuit's reasoning and reversed its decision. The court held that "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."
The decision criticized the Sixth Circuit for treating as irrelevant evidence that Williams was able to perform household chores and tend to personal hygiene.
Elements of this ruling will impact future disability discrimination cases in several ways. First, the Supreme Court held the word "substantial" in the definition of disability "clearly precludes impairments that interfere in only a minor way with the performance of manual tasks from qualifying as disabilities," and noted the impairment's impact must be "permanent or long term."
Second, it stated the phrase "major life activities" means activities "of central importance to daily life." The court held these terms "need to be interpreted strictly to create a demanding standard for qualifying as disabled" to be faithful to Congressional intent regarding the appropriate reach of the ADA.
In future ADA cases, it is likely courts will give heightened scrutiny to a plaintiff's claim of being disabled and therefore deserving of the protection of the ADA. The Supreme Court's rejection of the Sixth Circuit's broad standard will likely mean that claims in which the disability grows out of an inability to perform work-related tasks will be difficult to maintain. Robert Harris is a partner specializing in labor and employment law with the law firm of Vorys, Sater, Seymour and Pease LLP. He can be reached at the firm's Columbus office, (614) 464-6400, or visit www.vssp.com.