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U.S. Supreme Court Applies Narrow Definition of Disability

Volume 1, Issue 5
March 7, 2002

Court Says Manual Task Limitation Needs Both Daily Living and Workplace Impact

In an important decision clarifying the definition of “disability” under the Americans With Disabilities Act (ADA), the U.S. Supreme Court recently ruled that a Toyota assembly line worker was covered by the ADA only if her impairment affected her daily activities of living, and not just her ability to perform a specific task at work. Ella Williams suffered from carpal tunnel syndrome and tendonitis, and was under medical restrictions which prohibited her from fulfilling her job duties because she was not able to lift her arms above chest level. However, Williams was not prohibited from brushing her teeth, washing her face, bathing, tending to her flower garden, fixing meals, etc. Previously, the U.S. Court of Appeals for the Sixth Circuit had ruled that Williams was covered by the ADA because she was substantially limited in the major life activity of performing “manual tasks”. Overturning that decision, the Supreme Court criticized the Sixth Circuit for not recognizing that Williams maintained the ability to perform nearly all her own personal tasks. Writing for the Court, Justice Sandra Day O’Connor noted that, “Household chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives, and should have been part of the assessment of whether [Williams] was substantially limited in performing manual tasks”.

In narrowing the definition of "substantially limited in performing manual tasks," the Court emphasized that the language of the ADA requires that there is a “demanding standard for qualifying as disabled,” and therefore held that for manual tasks to fit into the category of major life activities, it is necessary for the manual tasks to be central to daily living. The ruling is a favorable one for employers as it narrows the standard by which an employee can be considered disabled and, therefore, covered by the ADA. This is particularly important given that so-called “ergonomic” claims have been on the rise. Following this decision, an employee can no longer claim himself disabled solely because he cannot perform one or more manual tasks that are part of his job–an employee must now show that he is impaired in his ability to perform “personal” tasks that transcend the workplace.

Toyota Motor Mfg., Kentucky, Inc. v. Williams , Case No. 00-1089 (Jan. 8, 2002).

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