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The U.S. Supreme Court has refined the definition of "disability" under the Americans with Disabilities Act (ADA) when it recently ruled on Toyota Mfg. Ky. Inc. v. Williams. In a 9-0 decision, the Court narrowed the "inability to perform manual tasks" basis of disability under the ADA to include only those people affected in both their personal and work lives, effectively shutting the door on cases brought by plaintiffs who sought to focus solely on workplace limitations.
Historically, in order for a physical or mental impairment to be considered a "disability" under the ADA, it must be shown to substantially limit a major life activity such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing and learning. Many individuals have attempted to claim they are "disabled" for ADA purposes because of their inability to perform the "manual tasks" required by the duties of their employment. This interpretation of disability focuses solely on the workplace environment, disregarding all other aspects of the individual's daily living.
Through its ruling in Toyota, the high Court has restricted this interpretation, holding that an individual who makes a claim under the ADA must be substantially limited in abilities that are "central to daily life," not just "manual tasks unique to any particular job." In its decision, the Court highlighted specific personal tasks such as "household chores, bathing, and brushing one's teeth" as those activities central to an individual's daily living which, if unable to perform, renders an individual "disabled" for ADA purposes.
In Toyota, the plaintiff suffered from carpal tunnel syndrome and was unable to perform the primary duties of her job. At trial, however, she testified that she was able to brush her teeth, wash her face, bathe, tend her flower garden, do laundry and many other activities of daily living. Because she was able to do these personal tasks and chores, the Court found she was not "substantially limited" as required by the ADA, ruling the question of impairment is not restricted to examining the ability to function in the workplace.
The Court went even further saying, "manual tasks unique to any particular job are not necessarily important parts of most people's lives" and therefore "occupational-specific tasks may have only limited relevance to the manual task inquiry." The Court held that, in reversing the trial court's summary judgment for Toyota, the Sixth Circuit Court of Appeals "disregarded the very type of evidence that it should have focused on."
For employers, this decision has considerable ramifications. No longer can employees claim ADA disability simply by showing the inability to do a manual task on the job. The ADA was created to protect individuals with significant limitations, not minor injuries or routine restrictions. The decision in Toyota shifts the emphasis in determining ADA disability to the individual's ability to function in his total world environment, not just on the job, allowing many employers to breathe a little easier.
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