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| Has the Definition of Disability Really Been Narrowed? Don't always believe what you read. Recent articles have stated that the Supreme Court ruled that to qualify as disabled, and therefore to be protected by the Americans With Disabilities Act (ADA), a person must have substantial limitations on abilities that are "central to daily life," and not only to life in the workplace. This statement overstates the holding of the Supreme Court, which was more limited. The actual holding of the case, Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, was that in order to be "substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives" - rather than just their work lives. Moreover, this decision will not have any impact on cases brought under the respective state disability laws of New York and California, so employers in those states should not alter their disability policies. The term "disability" under the ADA is defined as "a physical or mental impairment that substantially limits one or more of the major life activities of such individual." Merely having an impairment does not make one disabled for purposes of the ADA. Claimants also need to demonstrate that the impairment limits "a major life activity." To qualify as disabled, a claimant must further show that the limitation on the major life activity is "substantial." In Toyota, the plaintiff had carpal tunnel syndrome and therefore claimed that she was substantially limited in the major life activity of performing manual tasks. One 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. The Supreme Court found that the lower court's finding of disability was in error because it ignored the question of whether the limitations affected Mrs. Williams's daily life outside the factory. The Court stated that "[w]hen addressing the major life activity of performing manual tasks, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job." The Court stated 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 Court found that the repetitive work that caused Mrs. Williams's problem "is not an important part of most people's daily lives." 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. The Supreme Court ruled that it was not enough that her physical problems caused her difficulties in her job if they did not also disable her in activities at home. While the newspapers touted that ruling as a change in the law, the fact is that even before that Toyota case, courts had held that for a person to be disabled, he or she had to be unable to do whole classes of jobs -- not just the one job he or she happened to hold. Thus, the employee with carpal tunnel syndrome who could not do certain repetitive manual tasks could work in many other jobs that do not require such tasks -- and therefore she was not "disabled" under the ADA. Disability laws in both New York and California define the term "disability" much more broadly than the ADA. Thus, the Supreme Court's decision in Toyota will have an even smaller impact on employers in these two states. The New York Human Rights law defines "disability" as "a physical, mental, or medical impairment resulting from anatomical, physiological, genetic, or neurological conditions which prevents the exercise of a normal bodily function or is demonstrable by medically accepted clinical or laboratory diagnostic techniques." This definition does not include the concept of "major life activity." Under the New York Human Rights Law, therefore, a medically diagnosable condition, or an impairment demonstrable by medically accepted techniques, is a disability whether or not it limits a major life activity. Carpal tunnel syndrome is thus a disability under New York law and the Toyota case has no effect in cases under the New York Human Rights Law. Under the California Fair Employment and Housing Act, the definition of "disability" includes "having any physiological disease, disorder, condition, cosmetic disfigurement, or anatomical loss" that "limits an individual's ability to participate in major life activities." This definition reflects a legislative amendment in 2000 which now provides that a person is considered disabled if he or she is "limited" in one or more of the major life activities, as opposed to "substantially limited" in those activities as previously required and required by the ADA. Although California courts have not yet ruled on whether carpal tunnel syndrome constitutes a disability under this new definition, it seems that carpal tunnel syndrome would constitute a disability under California law as well. The Supreme Court's holding in Toyota thus has an even smaller impact (if it has an impact at all) in New York and California. The definition of "disability" in both of these states is far broader than it is under the ADA. As a result, the issue of whether an individual is limited in his or her ability to perform manual tasks both inside and outside of the office is not of much import. In both states, such individuals would most likely be considered disabled and employers should be concerned with providing reasonable accommodations for their disabilities. © 2002 Davis & Gilbert LLP |
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