The Supreme Court Significantly Narrows ADA Definition of "Disability;" Inquiry Extended to Daily Life Tasks

Employment Law Insider & Alert

PUBLISHED ON: December 31, 2002

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On January 8, 2002, the United States Supreme Court issued a unanimous opinion that will further hinder individuals asserting disability discrimination claims against employers under the Americans with Disabilities Act (“ADA”). In Toyota Motor Manufacturing, Kentucky, Inc. v. Williams (“Toyota Motor”), the Court limited the term “disability” to include only those which affect daily life activities rather than those activities which only are necessary to perform a certain job. “When 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 [the claimant’s] specific job,” the Court stated. As examples of such tasks, the Court referred to bathing, brushing one’s teeth, and the ability to perform household chores.

In Toyota Motor, the plaintiff alleged that she was disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, and sued her former employer for failing to provide her with a reasonable accommodation as required by the ADA. The district court granted the employer’s motion for summary judgment, and the United States Court of Appeals for the Sixth Circuit reversed, holding that the plaintiff was required to and did in fact demonstrate that her manual disability involved a “class” of manual activities affecting her ability to perform tasks as work. The Supreme Court reversed the decision of the Sixth Circuit, providing for a more restrictive interpretation of the term “disability.”

The ADA defines a “disability” as “a physical or mental impairment that substantially limits one or more of the major life activities” of an individual. In interpreting the terms “physical impairment” and “major life activity,” the Court looked to regulations issued by the Equal Employment Opportunity Commission (“EEOC”) and the Department of Health, Education and Welfare (“HEW”). The HEW regulations include “performing manual tasks” as an example of a “major life activity.” The regulations, however, do not define “significant” or “major,” which the Court noted are commonly defined as “to a large degree” and “important,” respectively. From these regulations and definitions, the Court interpreted “disability” to mean that the claimant must be unable to perform the variety of tasks central to most people’s daily lives. The Court also reasoned that because the ADA provides protection outside of the workplace, i.e. in public facilities and transportation, a court’s inquiry should not be limited to the effect of the disability on work-related tasks. Finally, the Court said that “the impairment’s impact must also be permanent or long term.”

This decision is just another step in the Court’s recent progression toward narrowing the scope of individual rights under the ADA. For example, in Sutton v. United Air Lines, Inc. and Murphy v. United Parcel Service, Inc., both of which were decided on June 22, 1999, the Supreme Court limited the scope of potential plaintiffs in disability suits by articulating a new element, the existence of mitigating measures, in determining whether an individual’s impairment qualifies her as “disabled” within the meaning of the ADA. Specifically, the Court stated that “[a] person whose physical or mental impairment is corrected by medication or other measures does not have an impairment that presently ‘substantially limits’ a major life activity.” Taken together, the recent decisions by the Court regarding the ADA limit the concept of who is or may be considered disabled under the statute, should limit the number of frivolous claims, and make it easier for employers to defeat ADA claims.

Practice Tip: While the Supreme Court decision in Toyota Motor sounds a major victory for employers, the decision also raises a number of questions to be answered by future cases: May an employer question prospective or current employees about the impact of a disability on non-work related activities? Will the Court’s opinion be extended to non-manual job functions and a broad range of stress-related and other psychological impairments? How will “permanent” or “long term” impairments be assessed?

Employers should also be aware that individuals may avail themselves of the broader protections still available under many state and local laws.

Members of our Labor and Employment Law Group would be happy to answer your questions about these Supreme Court rulings or other issues facing employers under the Americans with Disabilities Act.