Supreme Court Limits Application of the Americans with Disabilities Act
In a decision released on January 8th, the United States Supreme Court limited the reach of the Americans with Disabilities Act ("ADA"). The unanimous ruling in Toyota Motor Manufacturing, Kentucky, Inc. v. Williams is good news for employers who are concerned about the extent of the ADA's duty to reasonably accommodate employees with physical or mental impairments.
Ella Williams, a former employee of Toyota Motor Manufacturing, Kentucky, Inc., ("Toyota"), sued the company claiming that she was disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments and that the company had failed to reasonably accommodate her. The District Court granted Toyota's motion for summary judgment, finding, among other things, that Ms. Williams' impairment did not meet the definition of a "disability" under the ADA, since it did not "substantially limit" any "major life activity." The Sixth Circuit reversed, holding that the impairments substantially limited Ms. Williams in the major life activity of performing manual tasks. The Supreme Court found that the Sixth Circuit had not applied the proper standard when analyzing whether Ms. Williams was a person with a disability within the meaning of the ADA and reversed.
The Court's Reasoning
The Supreme Court disagreed with the Sixth Circuit's finding that in order for Ms. Williams to show that she was substantially limited in the major life activity of performing manual tasks, she needed to demonstrate that the manual disability involved a "class" of manual activities. The Supreme Court held instead that an employee must show that he/she is unable to perform the variety of tasks "central to most people's daily lives." Being substantially limited in the tasks associated with a particular job is insufficient to find that an individual has a disability under the ADA. Manual tasks unique to a specific job are not necessarily important parts of most people's lives, the Court said. Rather, it noted, tasks such as performing household chores, bathing, and brushing one's teeth are among the types of manual tasks of central importance to people's daily lives. The Court reversed and remanded the case for further proceedings.
Implications for Connecticut Employers
Although the Court made clear that the ADA imposes a demanding standard, its decision makes it equally clear that any inquiry must be individualized. Thus, a finding that any one particular employee's impairment is not a disability, does not mean that no employee with the same impairment could ever be considered to have a disability. Employers must go beyond the label applied to an employee's condition and look to the actual restrictions the condition places on the individual.
It is also important to remember that Connecticut's own anti-discrimination law defines "physically disabled" differently than the ADA. Connecticut's law arguably has a broader application, so it is possible that an employee who is not a person with a disability under the ADA could successfully bring suit under the state's disability protection laws.
As a result, any employer analyzing the applicability of the ADA to a particular situation must continue to conduct fact specific inquiries, taking into account both federal and state anti-discrimination laws.
For further information on the Americans with Disabilities Act, or any other employment related issue, please feel free to call John Zandy or Peter Lefeber in New Haven (203-498-4400), Steve Harris, Peter Wendzel or Marcia Keegan in Hartford (860-297-3700) or Larry Peikes in Stamford (203-363-7600).