Few issues in the area of employment law have given rise to as much uncertainty and consternation as the scope of the Americans with Disabilities Act of 1990 (the “ADA”), which prohibits discrimination against persons with disabilities. Much of the confusion stems from perhaps the most basic component of the ADA – the definition of the term “disability.” The ADA itself defines “disability” to mean “a physical or mental impairment that substantially limits one or more of the major life activities of such individual.” In many respects, however, this definitional language only compounds the problem. For as difficult as it is to ascribe meaning to the term “disability,” it is even more difficult to ascertain what is meant by “substantially limits” and “major life activities.” Thus, the question has persisted: What does an employee have to prove in order to be considered disabled under the ADA?
No doubt aware of the real-life consequences of the ADA’s ambiguous language, the United States Supreme Court recently offered some much needed guidance. In Toyota Motor Manufacturing, Kentucky, Inc. v. Williams , decided on January 8, 2002, the Court was presented with a fairly typical disability discrimination claim. The employee, Williams, worked on an automobile assembly line for Toyota and suffered from carpal tunnel syndrome and other related conditions. These conditions interfered with Williams’ ability to lift objects and to perform certain manual tasks. Williams also found it difficult to perform certain aspects of her job, including repetitive manual tasks that required her to keep her arms extended for long periods of time. Eventually, after she and Toyota disagreed about how to accommodate her physical condition, Williams began missing work on a regular basis and was eventually terminated.
Williams filed suit against Toyota, alleging that, by failing to grant her a reasonable accommodation and terminating her employment, the company discriminated against her because of her alleged disability. Although the trial court held that Williams’ condition did not satisfy the legal definition of disability, that decision was reversed by the Sixth Circuit Court of Appeals. Toyota then appealed the appellate court’s decision to the Supreme Court, which agreed to hear the case and to address the question of whether Williams’ condition rose to the level of a disability under the ADA.
In a decision that represents significant progress in the ongoing refinement of the ADA’s boundaries, the Supreme Court held that Williams’ carpal tunnel syndrome and related medical conditions did not render her disabled. The Court, in reaching this conclusion, focused on the ADA’s requirement that, in order to be considered disabled, an employee must demonstrate that his or her condition substantially limits a major life activity. Significantly, the Court explained that this requirement demands much more than a mere showing that the employee is unable to perform his or her particular job. Rather, the employee must prove that he or she suffers from a permanent or long-term impairment of his or her ability to perform activities of central importance to most people’s daily lives. Such major life activities include, by way of example, walking, seeing, and hearing. The Court explained that, where the medical condition at issue affects one’s ability to perform manual tasks, as does carpal tunnel syndrome, the employee must show that he or she is impaired in the performance of such activities as household chores, bathing, and brushing one’s teeth – all tasks of central importance to an ordinary person’s daily life.
Applying these principles to Williams’ case, the Court noted that the work-related functions that Williams could no longer perform – repetitive manual tasks with arms and hands extended – were no doubt important to her particular job, but are not of central importance to an ordinary person’s life. Thus, her inability to perform her job did not qualify her as disabled. Moreover, since Williams could still perform all of the manual tasks associated with an ordinary person’s daily life, from washing her face to doing laundry, the Court was unwilling to conclude that she was disabled.
It is important to note that Toyota v. Williams does not stand for the proposition that carpal tunnel syndrome can never constitute a disability under the ADA. Rather, the Court stressed that the impact of any impairment, whether carpal tunnel syndrome or some other condition, will vary from person to person. The Court, therefore, repeated its admonition from prior decisions that each case and each alleged disability must be evaluated separately, on a case-by-case basis.
In the end, the contribution of Toyota v. Williams is essentially two-fold. First, the Court confirmed that the mere fact that an employee cannot perform his or her job does not necessarily render the employee disabled. If, then, an employee is merely unable to perform a job-related task having no relation to an activity of central importance to an ordinary person’s life, it will have little if any impact in determining whether the employee is disabled.
Second, I also teaches that, when analyzing an employee’s ability to perform major life activities, the courts must focus only on those functions and tasks that are of central importance to an ordinary person’s life. This is an objective test. Even if the employee finds himself or herself unable to engage in a unique activity that has been of importance to his or her life, it will have no bearing on whether he or she is disabled if it is not the sort of basic activity that is central to an ordinary person’s life.
To some degree this standard eliminates a fair amount of the guessing that employers have engaged in when assessing their legal obligations to impaired employees. With the clarification provided by Toyota v. Williams, employers can more accurately make this assessment by evaluating whether there are any ordinary, day-to-day functions that the employee cannot perform. No doubt there will still be considerable uncertainty. Indeed, the ADA was couched in such vague and general terms that uncertainty will likely accompany ADA analysis for as long as the law is enforced. Even so, the Supreme Court’s decision in Toyota v. Williams goes a long way toward making at least one aspect of the process more predictable.