NU Online News Service, Jan. 8, 6:52 p.m. — Washington
The U.S. Supreme Court today issued a unanimous ruling that sets a high threshold for a sick or injured employee trying to prove the existence of a “disability” under the Americans with Disabilities Act.
ADA requires that, to be treated as a disability, a condition must substantially limit the performance of major life activities.
To meet the ADA standard, employees must demonstrate that they have impairments that prevent or severely restrict them from performing activities that are of central importance to the daily lives of most people, the Supreme Court said today in the decision.
In addition, the effects of the impairment must be permanent or long-term, the court said.
“It is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment,” the court said. “Instead, the ADA requires them to offer evidence that the extent of the limitation caused by their impairment in terms of their own experience is substantial.”
Patrick Clearly, senior vice president with the National Association of Manufacturers, Washington, praised the ruling.
“Today’s Supreme Court ruling makes it clear that the ADA is still the Americans with Disabilities Act, not the Americans with Injuries Act,” he said.
The decision?in the case of Toyota Motor v. Williams?involves a Toyota factory worker named Ella Williams, who claimed she had several impairments that substantially limited her ability to perform certain manual tasks on an assembly line.
Williams asked Toyota to accommodate her medical condition by allowing her to perform only certain tasks on the assembly line.
The parties are in dispute over what happened next. Williams claimed that Toyota refused her request and forced her to continue performing tasks that caused her even greater physical injury.
Toyota claimed that that Williams began missing work regularly, and that she was terminated due to a poor attendance record.
Williams filed a complaint with the Equal Employment Opportunities Commission and received a “right to sue” letter. She then filed suit against Toyota claiming the company violated the ADA by refusing to make a reasonable accommodation and terminating her employment.
The U.S. District Court for the Eastern District of Kentucky granted a summary judgment that Williams was not disabled under the terms of ADA.
While she did have a physical impairment, the court said, Williams was not substantially limited in any major life activity.
The court added that Williams did not submit sufficient evidence to demonstrate that she was substantially limited in lifting or working.
The 6th Circuit Court of Appeals reversed the district court. The 6th Circuit ruled that in order to show that she was disabled, Williams need only demonstrate that “her manual disability involved a class of manual activities affecting the ability to perform tasks at work.”
The 6th Circuit said the fact that Williams could tend to her own personal hygiene and carry out personal chores was immaterial, because such evidence would not affect a determination that she was substantially limited at work.
But, in an opinion written by Justice Sandra Day O’Connor, the Supreme Court said unanimously that “Merely having an impairment does not make one disabled for the purposes of ADA.”
The 6th Circuit erred, the Supreme Court said, because it analyzed only a limited class of manual tasks and did not ask whether Williams had impairments that prevented or restricted her from performing tasks that are of central importance to the daily lives of most people.