The Supreme Court on Tuesday limited the scope of a landmark federal law that prohibits discrimination against people with disabilities, rejecting a lower-court decision that would have classified more people as disabled and entitled to the law’s protection.
In a unanimous ruling involving a woman with carpal tunnel syndrome, the justices said lower courts must use a “demanding standard” to assess whether a person qualifies as disabled under the Americans with Disabilities Act, known as ADA. The more lenient approach, the court said, would run counter to Congress’ intent when it passed the law to protect the 43 million Americans with physical or mental disabilities.
“If Congress intended everyone with a physical impairment that precluded the performance of some isolated, unimportant or particularly difficult manual task to qualify as disabled, the number of disabled Americans surely would have been higher,” the court said, in an opinion by Justice Sandra Day O’Connor.
Instead, the impairment must be more substantial and prevent the person from doing activities that “are of central importance to most people’s daily lives,” the court said.
The justices sent the case back to the lower court to apply the different standard and decide whether autoworker Ella Williams was disabled under the law and could therefore continue with her lawsuit against Toyota Motor Manufacturing.
The ruling was a disappointment, though not a surprise, to disability rights advocates. Most characterized it as the latest in a string of Supreme Court rulings that have narrowed the reach of the law.
“This will just continue to draw the circle in tighter that you can step in to be covered,” said Chai Feldblum of Georgetown University Law School. “All of these cases are a distortion of what Congress intended to do when it passed the ADA.”
Business interests hail ruling
But lawyers representing business groups said the ruling was common sense.
“It’s pretty clear Congress intended the ADA to apply to a relatively well-defined class of individuals,” said Miriam Nemetz, a partner at Mayer, Brown & Platt, who wrote a brief on behalf of the Chamber of Commerce and other business organizations. “They certainly didn’t want everybody who had an impairment to be able to come into court and sue and demand that a job be tailored to their abilities.”
The disabilities law has consumed much of the court’s attention in recent terms as it has struggled to define whom the ADA covers and what it requires of employers. The law, passed amid fanfare in 1990 during the previous Bush administration, prohibits discrimination against disabled individuals in employment or public accommodations, such as restaurants, hotels and golf courses.
The law requires an employer to make reasonable accommodations for disabled workers, provided that they can do the essential functions of the job and that the accommodations would not impose an “undue hardship” on the employer.
Tuesday’s ruling focused on the threshold question of what constitutes a disability and whether a person was covered by the act in the first place. The law defines “disability” as impairment that “substantially limits” a person’s major life activity, such as seeing, breathing or, in this case, performing manual tasks.
1999 decision
The decision closely followed a 1999 ruling that also focused on the definition of disability. In that ruling, which involved United Airlines, the court said people who can correct physical impairments, such as nearsightedness or high blood pressure, are not disabled under the law.
The court said Congress never intended the law to cover workers who can correct their impairments by wearing glasses or using hearing aids or taking medication. Those people were not substantially limited in a major life activity, the court said.
“This decision fits right in with the ones the court already has decided,” said Ann Reesman, general counsel of the Equal Employment Advisory Council. “The court has said once again that the ADA protects individuals with a disability, which Congress defined as a distinct group of people–not every person on the street.”
The case that was decided Tuesday came about in 1997, when Williams sued Toyota, charging that the company refused to accommodate her disability. Four years earlier, she had settled a different ADA claim against Toyota.
Reassigned twice
Williams joined the company in 1990; she developed carpal tunnel syndrome and other symptoms after working on the assembly line. After the first lawsuit, Toyota assigned her to an inspection group. She was later given another assignment that she said exacerbated her condition.
Toyota refused to transfer her back to her old job and fired her in 1997 when she stopped coming to work. She sued, alleging that Toyota did not accommodate her disability.
A trial court threw out her lawsuit, agreeing with Toyota that her injury wasn’t a disability as defined by the law because she could do manual tasks, such as cleaning the house and gardening.
But the U.S. Court of Appeals for the 6th Circuit found Williams’ carpal tunnel syndrome qualified as a disability, ruling that her impairment reduced her ability to perform the “major life activity” of manual tasks associated with her job.
Life tasks vs. job tasks
In its ruling Tuesday, the justices said the appeals court’s approach was wrong. The appeals court should have focused on whether Williams’ impairment “severely restricts” her from doing “activities that are of central importance to most people’s daily lives,” not whether she was unable to perform the tasks associated with her job.
Those activities, the court said, include household chores, bathing and brushing one’s teeth.
Leslie Rosenbaum, Williams’ lawyer, said he believed she still would be able to pursue her lawsuit against Toyota, even under the tougher standard.
“It’s uncontradicted that Mrs. Williams cannot do repetitive manual activities and is restricted in lifting weights of greater than 10 pounds on a regular basis,” Rosenbaum said.
Rosenbaum declined to join those in the disability rights community who said the ruling would narrow the scope of the ADA. He suggested that lower courts will struggle to apply the decision and that related issues could be back before the high court.
The court will rule on at least two other ADA cases before its term ends in June. It heard arguments last month in a case that asks whether a US Airways employee was entitled to an accommodation for his disability, even if it would upset the company’s seniority system.
The second ADA case asks whether Chevron USA Inc. must hire a disabled man for a job that would pose a significant risk to his health or life.
