Contact: Steven B. Harz, Esq., Chairman
Labor & Employment Law Group
(201) 342-6000
UNITED STATES SUPREME COURT MAKES IT MORE
DIFFICULT FOR EMPLOYEES TO MAINTAIN CLAIMS
UNDER THE AMERICANS WITH DISABILITIES ACT
Dear Clients and Friends:
On January 8, 2002, the United States Supreme
Court issued a major decision regarding an employee’s ability to
maintain a lawsuit against an employer for a violation of the
Federal Americans with Disabilities Act (“ADA”). The practical
effect of the Court’s decision in Toyota Motor Manufacturing,
Kentucky, Inc. v. Williams will likely make it more difficult for
employees to demonstrate that they are “disabled” under the ADA
based on an injury that affects the employee’s ability to perform
the functions of the job, and in turn, hold their employers liable
for failing to make reasonable accommodations for their impairments.
Plaintiff Williams worked on an engine fabrication
assembly line in Toyota’s automobile manufacturing plant in Kentucky
where her duties included working with pneumatic tools. Continued
use of these tools caused pain in Williams’ hands, wrists and arms.
She was subsequently diagnosed with bilateral carpal tunnel syndrome
and bilateral tendinitis. For the next several years, Williams was
assigned to light-duty jobs in the Quality Control Inspections (“QCI”)
division, which included the visual inspection of cars for
scratches, dents, or other external flaws.
Toyota subsequently announced that it would
require all employees assigned to the QCI division to apply a
“highlight” oil to the bodies of cars passing along on the assembly
line. Wiping the cars with the required oil required Williams to
hold her hands and arms up around shoulder height for several hours
at a time. Williams then sued Toyota, claiming that the Company
failed to reasonably accommodate her disability under the ADA.
Williams based her disability claim on the ground that her physical
impairments “substantially limited” her ability to perform manual
tasks at the job.
After two lower courts issued inconsistent
rulings, the Supreme Court heard the case to determine the proper
standard for assessing when an individual is disabled under the ADA.
The definition of “disability” under the ADA is “a physical or
mental impairment that substantially limits one or more of the major
life activities of such individual,” including the performance of
manual tasks.
In recognizing the large potential differences in
the severity and duration of the effects of carpal tunnel syndrome,
the Court noted that a person’s carpal tunnel syndrome diagnosis, on
its own, does not indicate whether the individual has a disability
within the meaning of the ADA. Therefore, the Court concluded that
when addressing whether an individual is disabled under the ADA ,
the inquiry must be whether the employee is unable to perform the
variety of tasks central to most people’s daily lives (i.e., tending
to personal hygiene or household chores), and not whether the
employee is simply unable to perform the tasks associated with his
or her specific job description.
Since the Court concluded that manual tasks unique to any particular
job are not necessarily an important part of most people’s daily
lives, occupation-specific tasks only may have limited relevance in
determining whether an employee has a disability under the ADA.
As a result of this decision, employees will have
a more difficult time establishing that carpal tunnel syndrome is a
disability within the ambit of the ADA. While the Supreme Court did
not say that carpal tunnel syndrome could never amount to a
disability under the ADA, the Court affirmatively determined that
the question of whether an impairment constitutes a disability
cannot be answered solely by analyzing the effect of that impairment
in the workplace.
Thus, a court now must look at the effect of the
impairment on the employee’s life both inside as well as outside of
the workplace. If the employee can still perform manual tasks
outside of the workplace that are common to all people, such as
bathing, cleaning, or cooking, the employee would be hard-pressed to
demonstrate that an employer should be held liable under the ADA for
failing to make reasonable accommodations for the physical
impairment.
If you have any questions with regard to the
application of the Toyota v. Williams case to your Company or with
respect to any other labor and employment law matter, please do not
hesitate to contact Steven B. Harz, Esq. at (201) 342-6000 or via
e-mail at
sharz@hertenburstein.com.
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