January 9, 2002
NATIONAL
Justices Narrow Breadth of Law on Disabilities
By LINDA GREENHOUSE
WASHINGTON, Jan. 8 The Supreme Court ruled today that to qualify as
disabled, and therefore to be protected by the Americans With
Disabilities Act, a person must have substantial limitations on
abilities that are "central to daily life," and not only to life in the
workplace.
The unanimous ruling was the latest and one of the most important in a
series of Supreme Court decisions that have interpreted and, for the
most part, narrowed the broad terms of the 1990 law, which obligates
employers to make reasonable accommodations for disabled workers.
As a result, plaintiffs are finding it much more difficult than the
law's advocates expected to win their cases, or even to get into court
in the first place under increasingly stringent definitions of
disability.
Employers viewed the opinion today, by Justice Sandra Day O'Connor, as a
major victory. It overturned a lower federal court's finding that an
assembly line worker at a Toyota plant who suffered from carpal tunnel
syndrome, an ailment involving muscle and tendon injuries from highly
repetitive activities, was disabled in the "major life activity of
performing manual tasks."
The justices' ruling was not conclusive, leaving open the possibility
that the woman, Ella Williams, who worked for six years at the Toyota
plant in Georgetown, Ky., might still win her case when it goes back to
the United States Court of Appeals for the Sixth Circuit, in Cincinnati.
The appeals court had granted summary judgment to Mrs. Williams,
finding her disabled as a matter of law based on her inability to meet
the demands of her assembly line job and of other jobs that require
gripping tools and working with arms elevated and outstretched.
That was too narrow a focus on which to base a finding of disability,
Justice O'Connor said, because it ignored the question of whether the
limitations affected Mrs. Williams's daily life outside the factory.
"The central inquiry must be whether the claimant is unable to perform
the variety of tasks central to most people's daily lives," not just
those of a particular job, Justice O'Connor said, adding that "household
chores, bathing and brushing one's teeth are among the types of manual
tasks of central importance to people's daily lives" and should have
been part of that inquiry.
The repetitive work that caused Mrs. Williams's problem "is not an
important part of most people's daily lives," Justice O'Connor said.
Mrs. Williams had testified that while she needed help in dressing and
had given up such activities as sweeping and dancing, she could still
take care of her personal hygiene, cooking and some housework and
gardening. But the appeals court disregarded all the non-workplace
evidence. Without an evaluation of the full effect of Mrs. Williams's
impairment, summary judgment in her favor was inappropriate, Justice
O'Connor said.
"These changes in her life did not amount to such severe restrictions in
the activities that are of central importance to most people's daily
lives that they establish a manual-task disability as a matter of law,"
the opinion said.
While Mrs. Williams is not likely to prevail back in the lower court,
the decision could be helpful to plaintiffs whose limitations have more
effect outside the workplace than within it, said Prof. Chai Feldblum of
the Georgetown University Law Center.
"If brushing your teeth qualifies as an essential activity, then so do
other things like taking out the garbage" or lifting things around the
house, Professor Feldblum, a leading authority on the statute, said in
an interview.
Nonetheless, she said, the court's approach today is likely to pose new
problems for some plaintiffs, many of whom have already been shut out of
court by the Supreme Court's earlier rulings and by lower courts'
responses to those rulings.
In three decisions in 1999, the Supreme Court considered whether people
qualified as disabled if their conditions could be corrected or
controlled by medication or devices like eyeglasses. Corrective measures
must be taken into account in assessing disability, the court ruled.
Professor Feldblum said lower courts had interpreted the 1999 decisions
to hold that people with diabetes, epilepsy, prosthetic limbs and even
schizophrenia were not disabled.
As in 1999, the court today, in Toyota Motor Manufacturing Inc. v.
Williams, No. 00-1089, stressed a need for an individual, case-by-case
determination of disability rather than a conclusion based on a medical
diagnosis.
The adoption of the Americans With Disabilities Act in 1990 followed a
decade of debate over how discrimination on the basis of disability
should be treated legally. In enacting what many people regard as the
most important civil rights law of the last 25 years, Congress wrote in
very broad and general language, leaving much uncertainty about how the
law would be carried out in the real world of the workplace. In the
continuing legal battle, the courts are just now beginning to give
precision and content to the open-ended phrases of the statute.
The law defines disability as "a physical or mental impairment that
substantially limits one or more of the major life activities."
Disability can also be established by having "a record of such an
impairment" or "being regarded as having such an impairment,"
definitions that were not at issue in this case.
Justice O'Connor said the law's essential definitional terms
"substantially limits" and "major life activities" "need to be
interpreted strictly to create a demanding standard for qualifying as
disabled."
Congress made that clear, she said, by its reference in the law's
preamble to 43 million Americans who "have one or more physical or
mental disabilities." With 100 million people wearing corrective lenses,
she said, Congress obviously did not mean to include everyone with some
type of limitation.
The decision put off until another day answering the question of whether
"working" can be considered a "major life activity" under the statute.
Earlier Supreme Court decisions have suggested that it cannot be, but
Justice O'Connor said, "We need not decide this difficult question
today."
Although the court limited its discussion to the activity of "performing
manual tasks," disability law specialists agreed that the decision
extended beyond that category to create a kind of template for assessing
limitations on other "major life activities" as well.
"The message is clear that claims of disability status will be looked at
very closely," said Peter Susser, a lawyer with the firm of Littler
Mendelson who filed a brief for the National Association of
Manufacturers.
Stephen Bokat, executive vice president of the National Chamber
Litigation Center, the legal arm of the United States Chamber of
Commerce, called the decision a major victory for employers.
"The court understood," Mr. Bokat said, "that the A.D.A. was not meant
to create a loophole for people with routine limitations or minor
injuries, but was intended for people with significant limitations."
After Mrs. Williams, who is now 42, developed her repetitive motion
injury, Toyota at first accommodated her by assigning her to inspect the
paint on finished cars as they moved along a conveyor belt at the rate
of one a minute. That job involved minimal use of her arms.
But then Toyota required her to use a sponge to wipe oil on the cars.
Her physical problems returned. When Toyota refused to change her
assignment, she stopped coming to work. The company dismissed her, and
she sued.
The Toyota case is one of three cases involving the disability act that
are on the court's calendar for the current term.
US Airways v. Barnett, No. 00-1250, which was argued last month, poses
the question of whether employers must accommodate the needs of disabled
workers even if the accommodation overrides the seniority rights of
other workers.
Chevron v. Echazabal, No. 00-1406, to be argued next month, asks whether
an employer can refuse to hire someone whose disability would make the
job a threat to his own health or life.
E-mail Linda Greenhouse your questions at scotuswb@... with
"Supreme Court Q & A" in the subject line. Please include your name and
town in the message.
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