See also: Supreme Court Narrows Reach of Disability Law
http://www.nytimes.com/2002/01/08/national/08CND-SCOTUS.html?todaysheadlines
There is link to the actual decision, Toyota v Williams
Williams had a physical impairment, a form of carpel tunnel syndrome,
which she developed from using pneumatic tools during her initial employment
at Toyota. She settled a worker's compensation case and a prior ADA case
with the employer. As an accommodation under the settled ADA case, she was
given an inspection job where she did not have to use her hands in repetitive
motions or hold her hands at shoulder height for long periods of time. But
then the employer changed her job tasks so that she had to hold an object at
shoulder height for a long time and her carpel tunnel syndrome was
aggravated. At one point a doctor certified that she was unable to work, and
she missed days of work. The employer discharged her for lack of attendance
at work. Williams filed her second ADA action based upon the employer's lack
of accommodation to her disability.
The issue of the performance of job-specific tasks and the issue of
accommodation by the employer are never addressed because the courts focus on
the definition of disability under the ADA. The federal district court ruled
that Williams was not disabled, the federal court of appeals ruled that
Williams was disabled, and then the Supreme Court said that the court of
appeals had applied the incorrect interpretation of the definition of
disabled under the ADA and sent the case back down to the district court for
reconsideration in light of the Supreme Court's decision. The ADA in its
definition of disabled requires a physical impairment which substantially
limits one or more major life activities. The Supreme Court said it was not
deciding if working was a major life activity under that definition of
disabled under the ADA; the Supreme Court said that it was deciding whether
Williams could perform manual tasks as a major life activity under the ADA.
(This legal hairsplitting flows from how Williams' attorney framed the issues
in district court to avoid that issue of whether or not working was a major
life activity).
From Part IV of the Court's decision, citations deleted:
"While the Court of Appeals in this case addressed the different
major life activity of performing manual tasks, its analysis circumvented
Sutton [a previous case] by focusing on respondents inability to perform
manual tasks associated only with her job. This was error. 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 peoples daily lives, not whether the claimant is unable to perform the
tasks associated with her specific job. ***Even more critically, the manual
tasks unique to any particular job are not necessarily important parts of
most peoples lives. As a result, occupation-specific tasks may have only
limited relevance to the manual task inquiry. In this case, repetitive work
with hands and arms extended at or above shoulder levels for extended periods
of time, the manual task on which the Court of Appeals relied, is not an
important part of most peoples daily lives. The court, therefore, should not
have considered respondents inability to do such manual work in her
specialized assembly line job as sufficient proof that she was substantially
limited in performing manual tasks. At the same time, the Court of
Appeals appears to have disregarded the very type of evidence that it should
have focused upon. It treated as irrelevant [t]he fact that [respondent] can
ten[d] to her personal hygiene [and] carr[y] out personal or household
chores. Yet household chores, bathing, and brushing ones teeth are among the
types of manual tasks of central importance to peoples daily lives, and
should have been part of the assessment of whether respondent was
substantially limited in performing manual tasks. *** In addition, according
to respondents deposition testimony, even after her condition worsened, she
could still brush her teeth, wash her face, bathe, tend her flower garden,
fix breakfast, do laundry, and pick up around the house. The record also
indicates that her medical conditions caused her to avoid sweeping, to quit
dancing, to occasionally seek help dressing, and to reduce how often she
plays with her children, gardens, and drives long distances. But these
changes in her life did not amount to such severe restrictions in the
activities that are of central importance to most peoples daily lives that
they establish a manual-task disability as a matter of law." [Yikes!!!]
The U.S. Supreme Court, the final authority in the interpretation of
the ADA, clearly says that the definition of disability has to be
construed/interpreted strictly, narrowly, that congress intended that very
few people come within the protection of the ADA. Williams still has a last
shot at the district court level, but it is unlikely that the district court
will say that she is disabled. And I doubt if very many other people will be
found to be "disabled" now under the ADA. And if someone is found to be
"disabled" under this narrow definition, that person probably cannot peform
the job, any job, because the person is so impaired. Yikes!!!! The ADA may
not have been gutted here, but it sure looks like it. At a minimum persons
who seek the protections of the ADA will have to be very careful about the
definition of disability and the presentation of proof of disability. And
the issue of the ability to perform job-specific tasks will probably not be
discussed at all until after the person meets this incredibly high standard
of proof for a "disability." The Supreme Court also said that each case had
to be considered by itself and that a specfic diagnosis would not be
determinitive of "disability" under the ADA. To get any reasonable
protection under the ADA in the future, we may have to get Congress to change
the law and its definition of disability. Katie
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