High Court Limits Definition of Disability Under ADA
The Supreme Court unanimously ruled yesterday that people must have "substantial limitations" on activities "central to daily life," not only in the workplace, to qualify as disabled under the Americans with Disabilities Act, the New York Times reports (Greenhouse, New York Times, 1/9). The decision in Toyota Motor Manufacturing Inc. v. Williams "narrowed the scope" of the 1990 law and will "make it more difficult for workers to prove that they are ... entitled under the law to an accommodation by their employers," the Washington Post reports. In the court's opinion, Justice Sandra Day O'Connor wrote, "Merely having an impairment does not make one disabled for purposes of the ADA. Claimants also need to demonstrate that the impairment limits a major life activity" (Walsh, Washington Post, 1/9). She added that the "central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's lives, not whether the claimant is unable to perform the tasks associated with her specific job" (Richey, Christian Science Monitor, 1/9). In addition, she wrote that the impairment must have a "permanent or long-term" impact on the affected person (Denniston, Boston Globe, 1/9). In the case, Ella Williams, an employee at a Toyota manufacturing facility in Georgetown, Ky., sued her employer for refusing to make accommodations for her after she developed carpal tunnel syndrome, "contending that her condition prevented her from performing" her duties. A federal district judge dismissed the lawsuit in 1997, but a federal appeals court in Cincinnati reversed the decision. Toyota appealed the case to the Supreme Court (Washington Post, 1/9).
While the Supreme Court issued a decision on the definition of disability in the case, it did not rule on the merits of the case, "leaving open the possibility" that Williams still could win when the case returns to the 6th U.S. Circuit Court of Appeals in Cincinnati (New York Times, 1/9). Leslie Rosenbaum, Williams' attorney, said, "This case is a long way from being over." Rosenbaum plans to ask the appeals court to allow a jury to consider "whether or not the ability to perform repetitive manual activity is of central importance to daily lives." He said, "I think that a jury can look at this evidence and come to the conclusion that ... she can't do most of the same things that are of central importance in the lives of most people" (Murray, Washington Times, 1/9). The New York Times reports that Williams likely will not win the case, but the decision "could be helpful to plaintiffs whose limitations have more effect outside the workplace than within it" (New York Times, 1/9).
Pat Nepute, general counsel for Toyota's North American manufacturing operations, praised the Supreme Court's ruling. "The ADA was never intended to cover every relatively minor or routine workplace injury. ADA was intended to remove barriers that keep the truly disabled ... people out of the workplace," he said (Washington Times, 1/9). The Washington Post reports that the Supreme Court's decision yesterday could affect millions of employees who suffer from repetitive stress injuries or other impairments that affect their duties in the workplace (Washington Post, 1/9). Employers "hailed" the ruling and predicted that the decision would "shield employers from being sued or forced to make special arrangements" for employees with repetitive stress injuries (Savage, Los Angeles Times, 1/9). According to legal analysts, the ruling may either lead some employees to drop their cases in lawsuits against their employers for discrimination under ADA or prompt courts to dismiss the cases. The decision also will "put more of a burden" on employees to prove that they have a disability, which may "discourage" employees from filing lawsuits, analysts said (Armour, USA Today, 1/9). In addition, the ruling may "embolden employers who are already disinclined to make accommodations" for employees who claim to have a disability, Kathleen Blank, an attorney with the National Council on Disability said. Meanwhile, advocates for people with disabilities criticized the decision and said that the ruling would "prevent many individuals whom Congress intended ADA to cover from receiving its protection that they may need to secure and maintain employment."
Some reactions to yesterday's Supreme Court ruling from advocates for people with disabilities, employer groups and newspaper editorials appear below, in alphabetical order.
- Kathleen Blank, an attorney-adviser with the National Council on Disability: "This decision is going to give employers a lot of confidence that they can challenge workers on whether they are disabled ... giving them more latitude to refuse to make accommodations" (Washington Post, 1/9).
- Stephen Bokat, executive vice president of the National Chamber Litigation Center, the legal division of the U.S. Chamber of Commerce: "The court understood that the ADA was not meant to create a loophole for people with routine limitations or minor injuries, but was intended for people with significant limitations" (New York Times, 1/9).
- Patrick Cleary, senior vice president for the National Association of Manufacturers: "Today's ruling makes it clear that the ADA is still the Americans with Disabilities Act, not the Americans with Injuries Act" (Los Angeles Times, 1/9).
- Andrew Imparato, president of the American Association of People with Disabilities: "[The ruling] ultimately means that more people with disabilities never reach the issue of whether or not they were discriminated against, because their case gets thrown out" (Herman, New York Daily News, 1/9).
Investor's Business Daily: "This ruling is not the last word on ADA jurisprudence. ... But the ruling does clarify for employers what a covered disability is. For that, businesses should cheer" (Investor's Business Daily, 1/9).
- Arlene Mayerson of the Disability Rights Education and Defense Fund: "The worry is that this is one more signal by the court that's it's going to hold the bar [of the definition of disability] very high. It's very disappointing" (Biskupic, USA Today, 1/9).
- Jeffrey Rosen of the National Council on Disability: "It will have a chilling effect on people's ability to obtain and maintain employment" (Armour, USA Today, 1/9).
- William Stothers, a spokesperson for the Center for an Accessible Society: "It's going to be much more difficult for people to seek protection from the [ADA] if problems occur on the job" (Gearan, AP/Philadelphia Inquirer, 1/9).
- Washington Post: "This may seem like a stingy reading that will deny justified protection to workers, but the justices are right. The ADA is designed to prevent real discrimination against the disabled, not to compensate workers for every injury suffered on the job" (Washington Post, 1/9).
To view the Supreme Court decision, go to http://www.supremecourtus.gov/opinions/01pdf/00-1089.pdf. Note: You must have Adobe Acrobat Reader to view the decision. To listen to an NPR "All Things Considered" report on the decision, go to http://www.npr.org/ramfiles/atc/20020108.atc.ram. Note: You must have RealPlayer Audio to listen to the report.
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