- The United States Supreme Court Narrows the Definition of Disability
- May 2, 2003 | Author: Anne M. Radolinski
- Law Firm: Fredrikson & Byron, P.A. - Minneapolis Office
In a decision issued in January 2002, the United States Supreme Court effectively narrowed the coverage of the federal Americans with Disabilities Act ("ADA"). In a decision long awaited by the defense bar, the Court ruled that, in order to invoke the protections of the ADA, an individual must prove that he or she has a physical or mental impairment that "prevents or severely restricts the individual from engaging in activities that are of central importance to most people's daily lives," and that the impairment's "impact must . . . be permanent or long-term." Toyota Motor Manufacturing, Kentucky, Inc. v. Williams.
Williams had maintained that she was prevented from performing her automobile assembly line job by carpal tunnel syndrome and related impairments. She instituted an action against her employer, alleging that the company had failed to provide her with reasonable accommodations required by the ADA. The District Court dismissed her claims, ruling that her impairment did not qualify as a disability under the Act. The Sixth Circuit Court of Appeals disagreed and reinstated her claims. The Supreme Court reversed the Court of Appeals and remanded the case to the District Court.
The Supreme Court emphasized that it is insufficient for individuals who seek the protections of the ADA to produce a medical diagnosis of an impairment. They must show that that the limitation caused by the impairment is substantial. The label put on a condition or impairment is not controlling. The courts are required to engage in an individualized assessment as to whether the impairment, in regard to that particular individual, is permanent or long term and prevents or severely restricts the individual from engaging in activities that are of central importance to daily life. This is especially true with impairments such as carpal tunnel whose symptoms vary widely from individual to individual.
We anticipate that the Toyota Motor decision will go a long way to clear the courts of claims involving impairments that were not meant to be afforded the protections of the ADA. Since passage of the Act, the courts and the Equal Employment Opportunity Commission have been deluged with claims involving temporary impairments or impairments that could not be viewed to substantially limit an individual's major life activities, such as certain back problems, eye sight issues, carpal tunnel, weight issues, issues relating to stress and/or anxiety, minor mental health issues, and other less severe conditions. The Toyota Motor decision will have a significant positive impact on the defense of litigation and agency claims under the ADA.
Minnesota employers should note that the decision is an interpretation of the federal law, not state or local disability discrimination prohibitions as those under the Minnesota Human Rights Act and local ordinances, which are widely viewed as more expansive than the federal protections. In addition, the Toyota Motor decision, while very welcome, does not alter our strong recommendation to employers to seek guidance regarding employment decisions affecting individuals with physical or mental impairments. The definitions and prohibitions under the ADA and state and local laws affording protections against disability discrimination remain complex, and the potential for costly litigation resulting from an inadvertent misstep will continue to be substantial. Please do not hesitate to contact us for guidance in the handling of employment issues relating to individuals with physical or mental impairments.