G Employment Alert June 2002 Limiting Coverage Under the Americans with Disabilities Act By Martha L. Lester, Esq. and John D. Coyle, Esq. n the recent case of Toyota Motor Williams began missing work on a regular basis. I Manufacturing, Kentucky, Inc. v. Williams , the Her medical problems worsened and her doctors United States Supreme Court greatly limited said she was medically unable to work. She was the scope of the Americans with Disabilities Act terminated shortly thereafter for poor attendance. (the “ADA”). A unanimous Supreme Court reversed the Sixth Circuit Court of Appeals and “...the United States Supreme Court continued a recent trend of limiting the protection greatly limited the scope of the of the ADA. Americans with Disabilities Act .” Plaintiff Ella Williams had been a worker at a Toyota assembly plant in Kentucky since 1990. Williams filed suit under the ADA and the After working on the engine fabrication line with Kentucky Civil Rights Act, alleging that Toyota pneumatic tools, she developed pain in her hands, failed to reasonably accommodate her disability wrists and arms. For the next two years she worked and terminated her employment. In her claim, in various modified duty jobs and spent some time Williams alleged that she was disabled under the on medical leave. In December 1993, she was ADA because her physical impairments placed on a team in Quality Control Inspection substantially limited her in manual tasks, Operations, where she was able to perform two of housework, gardening, playing with her children, the four inspection processes. In 1996, Toyota lifting, and working, all of which, constituted announced that it wanted all Quality Control “major life activities” under the Act. Inspectors to rotate through all four of the processes. The ADA was enacted by Congress in 1990 with the stated purpose “to provide a clear and Shortly after she began working all four comprehensive national mandate for the stations, Williams experienced pain in her neck and elimination of discrimination against individuals shoulders. She was diagnosed with a number of with disabilities.” The ADA requires covered conditions including myotendinitis, thoracic output employers to provide reasonable accommodations compression, and carpal tunnel syndrome. to the known physical or mental limitations of Williams claims that Toyota insisted that she otherwise qualified employees with a disability, continue working and Toyota maintains that unless the employer can demonstrate that the This document is published by Lowenstein Sandler PC to keep clients and friends informed about current issues. It is intended to provide general information only. L Roseland, New Jersey Telephone 973.597.2500 65 Livingston Avenue www.lowenstein.com 07068-1791 Fax 973.597.2400
G accommodation would impose an undue hardship. specific job.” The Court determined that physical The ADA defines a disability as “a physical or impairments that affect only the manual tasks mental impairment that substantially limits one or associated with a particular job are not necessarily more of the major life activities” of the employee. important parts of most people’s lives. Therefore, impairments that only affect one’s ability to work The District Court granted Toyota’s motion for are not covered by the Act. summary judgment, finding that Williams was not disabled under the ADA or Kentucky Civil Rights The Supreme Court stated that repetitive work Act at the time Toyota refused to accommodate with hands or arms over your head for a prolonged her. The Court of Appeals reversed the District time, a manual task which Williams was unable to Court, granting partial summary judgment for perform, was not an important part of most Williams, finding that she was disabled for the people’s everyday lives. The Court found support purposes of the ADA. for this in the wording Congress used in the findings and purpose section of the ADA. In this The Court of Appeals held that the proper test findings section of the ADA, Congress found that to determine whether there was a substantial 43,000,000 Americans have one or more physical limitation in the major life activity of performing or mental disabilities. Justice O’Connor wrote that manual tasks was whether the disability involved a if Congress intended everyone with an isolated class of manual activities and whether those impairment to be considered disabled under the activities affected the ability of the employee to ADA, the number would be far greater (noting perform tasks at work. It found that Williams met that more than 100,000,000 people need this test since her ailments prevented her from corrective lenses to see properly). performing many of the manual tasks associated with her manual assembly line jobs, which required The Supreme Court defined major life the gripping of tools and repetitive work with arms activities as those that are of central importance to and hands extended for prolonged periods of time. daily life and affect such basic activities as walking, The court held that the injuries to Williams were seeing and hearing. Thus, a person suffering from “analogous to having missing, damaged or physical impairment, such as carpal tunnel deformed limbs that prevent her from doing the syndrome, will be considered disabled under the tasks” that are required to perform her job. ADA only if the impairment affects these core activities. Impairments that affect one’s ability to Justice Sandra Day O’Connor speaking for the perform his or her job only are not covered under unanimous Supreme Court reversed the decision the ADA. of the Court of Appeals, finding that it applied the incorrect test. The Supreme Court held that the The plaintiff stated that her disability caused “central inquiry must be whether the claimant is her “to avoid sweeping, to quit dancing, to unable to perform the variety of tasks central to occasionally seek help dressing, and to reduce how most peoples daily lives, not whether the claimant often she plays with her children, gardens, and is unable to perform the tasks associated with her drives long distances.” The Court did not find this
G persuasive since she could “still brush her teeth, A Practical Guide to wash her face, bathe, tend her flower garden, fix New Jersey Employment Law: breakfast, do laundry, and pick up around the The Employer’s Resource house.” Justice O’Connor held that it was incorrect, as a matter of law, for the Court of Appeals to find Williams disabled since her major You may also wish to obtain a copy of our life activities were not affected. newly published book, “A Practical Guide to New Jersey Employment Law: The Employer’s It can be expected that this decision will greatly Resource ,” Martha L. Lester, Executive Editor. reduce the number of employee claims that are This Guide , published in connection with the covered by the ADA. However, this will not mean New Jersey Business & Industry Association, is that employees are left without recourse. Most the resource for New Jersey employers seeking to states also have disability or handicap protection comply with New Jersey laws, regulations and laws that parallel the ADA and have lower procedures in the employment-related area. It thresholds for application. This decision will not provides management with information limit the scope of injuries covered by these state concerning existing laws, emerging trends, most laws and the federal law in this area will continue frequently asked questions, and practical tips on to evolve. managing the workforce and workplace. If you have any further questions about the issues Ordering Information : raised in this Alert and how they impact workplace New Jersey Business & Industry Association compliance issues, please do not hesitate to call Martha Members: $60 L. Lester, Chair of the Employment Law Practice Nonmembers: $90 Group, or John D. Coyle, a member of the � 6% NJ sales tax Employment Law Practice Group, at (973) 597-2500. � No charge for shipping and handling To order please call Dawn Miller at NJBIA at 609.393.7707 ext. 224
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