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Employment Alert

June 2002

Limiting Coverage Under the Americans with Disabilities Act

By Martha L. Lester, Esq. and John D. Coyle, Esq.

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n the recent case

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Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, the United States Supreme Court greatly limited the scope of the Americans with Disabilities Act (the “ADA”). A unanimous Supreme Court reversed the Sixth Circuit Court of Appeals and continued a recent trend of limiting the protection

• f the ADA.

Plaintiff Ella Williams had been a worker at a Toyota assembly plant in Kentucky since 1990. After working on the engine fabrication line with pneumatic tools, she developed pain in her hands, wrists and arms. For the next two years she worked in various modified duty jobs and spent some time

• n medical leave. In December 1993, she was

placed on a team in Quality Control Inspection Operations, where she was able to perform two of the four inspection processes. In 1996, Toyota announced that it wanted all Quality Control Inspectors to rotate through all four of the processes. Shortly after she began working all four stations, Williams experienced pain in her neck and

• shoulders. She was diagnosed with a number of

conditions including myotendinitis, thoracic output compression, and carpal tunnel syndrome. Williams claims that Toyota insisted that she continue working and Toyota maintains that Williams began missing work on a regular basis. Her medical problems worsened and her doctors said she was medically unable to work. She was terminated shortly thereafter for poor attendance. Williams filed suit under the ADA and the Kentucky Civil Rights Act, alleging that Toyota failed to reasonably accommodate her disability and terminated her employment. In her claim, Williams alleged that she was disabled under the ADA because her physical impairments substantially limited her in manual tasks, housework, gardening, playing with her children, lifting, and working, all of which, constituted “major life activities” under the Act. The ADA was enacted by Congress in 1990 with the stated purpose “to provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” The ADA requires covered employers to provide reasonable accommodations to the known physical or mental limitations of

• therwise qualified employees with a disability,

unless the employer can demonstrate that the

“...the United States Supreme Court greatly limited the scope of the Americans with Disabilities Act .”

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accommodation would impose an undue hardship. The ADA defines a disability as “a physical or mental impairment that substantially limits one or more of the major life activities” of the employee. The District Court granted Toyota’s motion for summary judgment, finding that Williams was not disabled under the ADA or Kentucky Civil Rights Act at the time Toyota refused to accommodate

• her. The Court of Appeals reversed the District

Court, granting partial summary judgment for Williams, finding that she was disabled for the purposes of the ADA. The Court of Appeals held that the proper test to determine whether there was a substantial limitation in the major life activity of performing manual tasks was whether the disability involved a class of manual activities and whether those activities affected the ability of the employee to perform tasks at work. It found that Williams met this test since her ailments prevented her from performing many of the manual tasks associated with her manual assembly line jobs, which required the gripping of tools and repetitive work with arms and hands extended for prolonged periods of time. The court held that the injuries to Williams were “analogous to having missing, damaged or deformed limbs that prevent her from doing the tasks” that are required to perform her job. Justice Sandra Day O’Connor speaking for the unanimous Supreme Court reversed the decision

• f the Court of Appeals, finding that it applied the

incorrect test. The Supreme Court held that 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.” The Court determined that physical impairments that affect only the manual tasks associated with a particular job are not necessarily important parts of most people’s lives. Therefore, impairments that only affect one’s ability to work are not covered by the Act. The Supreme Court stated that repetitive work with hands or arms over your head for a prolonged time, a manual task which Williams was unable to perform, was not an important part of most people’s everyday lives. The Court found support for this in the wording Congress used in the findings and purpose section of the ADA. In this findings section of the ADA, Congress found that 43,000,000 Americans have one or more physical

• r mental disabilities. Justice O’Connor wrote that

if Congress intended everyone with an isolated impairment to be considered disabled under the ADA, the number would be far greater (noting that more than 100,000,000 people need corrective lenses to see properly). The Supreme Court defined major life activities as those that are of central importance to daily life and affect such basic activities as walking, seeing and hearing. Thus, a person suffering from physical impairment, such as carpal tunnel syndrome, will be considered disabled under the ADA only if the impairment affects these core

• activities. Impairments that affect one’s ability to

perform his or her job only are not covered under the ADA. The plaintiff stated that her disability caused her “to avoid sweeping, to quit dancing, to

• ccasionally seek help dressing, and to reduce how
• ften she plays with her children, gardens, and

drives long distances.” The Court did not find this

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persuasive since she could “still brush her teeth, wash her face, bathe, tend her flower garden, fix breakfast, do laundry, and pick up around the house.” Justice O’Connor held that it was incorrect, as a matter of law, for the Court of Appeals to find Williams disabled since her major life activities were not affected. It can be expected that this decision will greatly reduce the number of employee claims that are covered by the ADA. However, this will not mean that employees are left without recourse. Most states also have disability or handicap protection laws that parallel the ADA and have lower thresholds for application. This decision will not limit the scope of injuries covered by these state laws and the federal law in this area will continue to evolve. If you have any further questions about the issues raised in this Alert and how they impact workplace compliance issues, please do not hesitate to call Martha

• L. Lester, Chair of the Employment Law Practice

Group, or John D. Coyle, a member of the Employment Law Practice Group, at (973) 597-2500.

A Practical Guide to New Jersey Employment Law: The Employer’s Resource

You may also wish to obtain a copy of our newly published book, “A Practical Guide to New Jersey Employment Law: The Employer’s Resource,” Martha L. Lester, Executive Editor. This Guide, published in connection with the New Jersey Business & Industry Association, is the resource for New Jersey employers seeking to comply with New Jersey laws, regulations and procedures in the employment-related area. It provides management with information concerning existing laws, emerging trends, most frequently asked questions, and practical tips on managing the workforce and workplace. Ordering Information: New Jersey Business & Industry Association Members: $60 Nonmembers: $90

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