Supreme Court Narrows Scope
of ADA Disabilities

Think you've got a disability that qualifies you for an accommodation at work because you otherwise can't perform your job duties? Maybe not under a new standard established by the United States Supreme Court.

In a case entitled Toyota v. Williams, the Supreme Court recently held that an auto-assembly plant worker's carpal tunnel syndrome did not impair a "major life activity" and under the Americans with Disabilities Act (ADA) required no employer accommodation. The Court reversed a contrary decision by a lower federal court because that court analyzed only a limited class of manual tasks associated with Ella Williams's job on a Toyota assembly line.

The ADA defines an individual with a disability as a person who has a physical or mental impairment that substantially limits one or more major life activities, or a person regarded as having, or with a history of having, such an impairment.

The ADA doesn't specify qualifying impairments. It defines major life activities as activities that an average person can perform with little or no difficulty. The Equal Employment Opportunity Commission regulations identify as major life activities walking, breathing, seeing, hearing, speaking, learning and working.

Before the ADA requires an employer to accommodate an employee with a qualifying disability, the employee must also demonstrate an ability to perform essential job duties with or without reasonable accommodation.

In holding that Ms. Williams's disability did not qualify her as "disabled" under the ADA, the Court established a new standard for use in determining whether an employee suffers a substantial impairment of a major life activity.

Under this standard, an employer must inquire whether an employee's impairment prevents or "severely restricts" the performance of activities that are of central importance to most people's daily lives, such as tending to personal hygiene and carrying out personal or household chores. An individual's inability to perform the tasks associated with his/her specific job does not qualify the individual as "disabled" under the ADA.

Until this decision, most employers accepted a medical diagnosis of a physical or mental impairment as sufficient to determine whether an employee qualifies as disabled. Now an employer must take a somewhat intrusive survey of the employee's activities outside the workplace.

This case-by-case analysis will consume considerably more time than most employers are accustomed to investing and will subject employees to what many may view as an invasion of privacy. However, the Supreme Court's substantial narrowing of who is considered "disabled" under the ADA will now allow employers to spend more time and resources accommodating individuals envisioned by Congress as entitled to coverage under the ADA, i.e., those whose disabilities substantially limit life's varied activities.

At MCCCD, staff members in the Employee Services Department determine whether an individual qualifies as "disabled" under the ADA.

If you believe a physical or mental impairment substantially limits your major life activities and requires a job accommodation, contact Judy Boyd, Manager of Employee Relations, at 480-731-8473.

Published in the Winter 2002 Edition of In Brief