Supreme Court Sets Tighter Standards For Employees With Disability Claims
Recently, in Toyota Manufacturing, Kentucky, Inc. v. Ella Williams, the Supreme Court made clear that the Americans with Disabilities Act (“ADA” or “Act”) imposes strict standards for finding “disability” status under the Act. While the case specifically addressed limitations on manual tasks caused by carpal tunnel syndrome and other conditions, the Court made clear that the Act generally should be strictly construed to create a “demanding standard” for an individual to qualify as “disabled” under the Act.
The Facts and Findings in Toyota Manufacturing, Kentucky, Inc. v. Williams:
In this case, the Petitioner Toyota Manufacturing, Kentucky, Inc. (“TMKI” or “the Company”) challenged the 6th Circuit Court of Appeals’ determination that Respondent Ella Williams (“Williams”) was “disabled” under the ADA because she was limited in certain manual work. Specifically, she could not perform repetitive work with her hands and arms extended at or above shoulder levels for extended periods of time.
Williams had worked several years for TMKI as an assembly line worker. As a result of some prior work-related injury, including carpal tunnel syndrome, she was assigned to work in the Employer’s Quality Control Inspection Operations (“QCIO”). QCIO involved four separate tasks and initially Plaintiff was assigned to rotate between two of those tasks: “assembly paint” and “paint second inspection.” “Assembly paint” required a visual inspection of cars as they moved down an assembly line to check for any flaws in the paint jobs of cars. “Paint second inspection” required the team member to wipe each car with a glove as it passed down a conveyor belt.
After a few years of this arrangement, TMKI decided that all employees who were assigned to QCIO would be required to rotate through all four of the QCIO tasks. One of the two additional tasks, “shell body audit,” required the assigned team member to hold her hands and arms at shoulder height for several hours at a time. After Williams began to rotate through the two additional tasks, she developed pain in her neck and shoulders which was diagnosed as various forms of tendinitis and nerve compression. Williams requested that she be returned to rotating only through the assembly paint and paint second inspection tasks. The Company refused, and Williams was terminated shortly thereafter for poor attendance. Williams sued under the ADA claiming that the Company failed to reasonably accommodate her and terminated her, both in violation of the ADA.
The Supreme Court made clear that to establish disability status, Williams needed to demonstrate that her impairments prevented her from performing tasks that are significant in most peoples’ lives. “It is insufficient for individuals attempting to prove disability status . . . to merely submit evidence of a medical diagnosis of an impairment,” Justice O’Connor wrote. One-quarter of carpal tunnel syndrome cases, she noted, are resolved within a month, even without surgery. The Court explained that although Williams was limited in performing her work tasks at the Company because she had carpal tunnel syndrome and tendonitis, her ability to perform personal tasks and chores was relevant to show that she was not “substantially limited” as required by the ADA.
What This Means for Employers
1. The ADA does not confer protection upon employees with impairments that are inconsequential or simply inconvenient.
2. Mere diagnosis of an impairment alone is not sufficient to confer ADA coverage – the impairment must prevent or severely restrict that person from performing an activity of “central importance to most peoples’ lives.”
3. In considering whether an impairment, such as carpel tunnel syndrome, substantially impairs a person’s ability to perform “manual tasks,” look to all manual tasks in a person’s life, not merely those required for the individual’s job.
But Don’t Forget…
4. Other laws, such as the Family and Medical Leave Act, Workers’ Compensation laws, and state and local disability laws, still should be thoroughly considered in making decisions regarding sick or impaired workers.