On January 8, the U.S. Supreme Court issued a unanimous decision that provided clarification on the issue of what may constitute a disability under the Americans with Disabilities Act (“ADA”). In Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, 534 U.S. __ (2002), the employee claimed that she was disabled from performing her automobile assembly line job due to carpal tunnel syndrome and related impairments, and sued her employer claiming that it had not provided reasonable accommodations as required under the ADA.
The Supreme Court in Toyota held that Ms. Williams was not disabled under the meaning of the ADA because she was not “substantially limited” in the “major life activity” of performing manual tasks. In general, in order to be entitled to reasonable accommodation under the ADA an individual must show that he or she suffers from an illness or injury that “substantially limits” a “major life activity.” In the Toyota case, the court said that it is not enough to show that Ms. Williams was substantially limited in her ability to perform manual tasks at work. Rather, the court held that the central inquiry is whether Ms. Williams was unable to perform the variety of tasks central to most people’s lives.
The Supreme Court explained that because manual tasks unique to any particular job are not necessarily important parts of most people’s lives, occupation-specific tasks may only have a limited relevance to the manual task issue. In short, the court stated that in this case, repetitive work with hands and arms extended at or above shoulder levels for extended periods is not an “important part of most people’s daily lives.” The court went on to state that household chores, brushing one’s teeth, and bathing are the types of manual tasks that are of “central importance to people’s daily lives” and should be part of the assessment as to whether Ms. Williams was substantially limited in performing manual tasks. The Supreme Court ruled that Ms. Williams was not substantially limited in the major life activity of performing manual tasks as she was able to wash her face, bathe, tend to her flower garden, fix breakfast and do laundry.
As a result of the Supreme Court’s decision in Toyota, if you believe you are disabled under the ADA and require accommodations in the activity of performing manual tasks, you must show that you are substantially limited in your ability to perform the type of manual tasks that are central to most people’s daily lives, such as doing laundry, bathing and brushing your teeth.
** This information is provided by the attorneys at Passman & Kaplan, P.C., a law firm dedicated to the representation of federal employees worldwide. For more information on Passman & Kaplan, P.C., go to http://www.passmanandkaplan.com. **