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Supreme Court Limits ADA Definition of “Disability” With Regard To Ergonomic-Related Injuries

An unanimous U.S. Supreme Court held an employee with carpal tunnel syndrome and tendonitis, which impaired her performance of manual tasks on the job, is not “disabled” within the meaning of the Americans with Disabilities Act (ADA) in Toyota Motor Mfg. v. Williams, 2002 WL 15402 (2002).  The employee, Williams, developed her ailments from use of pneumatic tools, and her doctor recommended restrictions, including discontinued use of such tools.  Toyota assigned Williams to an area where people with disabilities or medical restrictions were normally placed, but the carpal tunnel and tendonitis returned in a more severe fashion.  When Williams’ doctor added further medical restrictions, Toyota refused to assign her to only paint inspection duties.  Williams was fired when she failed to show up for work. 

The Court’s “central inquiry” was whether Williams was “unable to perform the variety of tasks central to most people’s daily lives, not whether [Williams] is unable to perform the tasks associated with her specific job.”  The ADA requires an employer to accommodate an ailment only if it “substantially limits” the ability to perform “major life activities.”  Thus, the presence of a disability cannot be assessed by looking solely at an individual’s fitness to work.  Rather, the Court requires a specific inquiry into manual tasks such as “household chores, bathing, and brushing one’s teeth,” since these are “of central importance to people’s lives.” 

While the decision is a victory for employers, its importance is limited.  First, the Court specifically noted that the ADA requires a case-by-case inquiry.  Thus, since ailments like carpal tunnel syndrome vary in degree, some employees with similar injuries may be able to prevail on an ADA claim.  Also, while the Court’s decision makes certain ADA cases harder to win, employers still must spend resources to look broadly into a plaintiff’s personal life and defend the suit.