ADA: U.S. Supreme Court to address whether carpel tunnel constitutes a disability

On April 16, 2001, the U.S. Supreme Court granted certiorari to hear a case involving discrimination against an employee with carpal tunnel syndrome under the Americans with Disabilities Act of 1990 (ADA).1 By accepting this case, the Court will have the opportunity to address the crucial issue of what constitutes a disability.

Factual background

In 1990, respondent Ella Williams went to work at an assembly plant for petiboner Toyota Motor Manufacturing in Kentucky and was assigned to an assembly line that produced engines. Within months, as a result of her prolonged use of pneumatic tools, she developed symptoms for carpal tunnel syndrome and other repetitive stress injuries in her wrists, neck, and arms. Williams sued under the ADA2 in 1993, and the case was settled.3

Williams returned to Toyota in December of that year with a doctor's instructions to perform only light duty. Toyota gave her two low-stress jobs on the Quality Control Inspections Operations unit, thereby transferring her away from her previous assembly line job, which was more strenuous. Williams worked at the two inspection jobs successfully for three years.4

In 1996, Toyota told Williams that all quality inspectors must be able to do all four inspection jobs interchangeably, not just two of them. Williams tried one of the new tasks, which required her to grip a block of wood and to keep her hands and arms around shoulder height repetitively over several hours. As a result, her ligament and muscle problems reappeared, and she also developed repetitive stress injuries in her shoulders and neck. Williams requested to be assigned back to her former inspection jobs. According to Williams, Toyota refused to allow her to return to these jobs and she was then fired. Hence, Williams filed suit in federal district court, alleging that Toyota had violated the ADA by not permitting her to return to her former, less taxing job.5

Pertinent rules of law

Title I of the ADA prohibits discrimination by any covered entity "against a qualified individual with a disability because of the disability of such an individual in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training and other terms, conditions, and privileges of employment."6 In pertinent part, the ADA defines the term "disability" as a "physical or mental impairment that substantially limits one or more of the major life activities of such individual."7 The forms of employment discrimination prohibited by Title I include "not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless [the employer] can demonstrate that the accommodation would impose an undue hardship on the operation of the business."8

The Equal Employment Opportunity Commission (EEOC) regulations implementing Title I of the ADA define "major life activities" to include "functions such as caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working."9 In addition, the regulations provide that an impairment "substantially limits" an individual if, as a result of the impairment, the person is (1) "[u]nable to perform a major life activity that the average person in the general public may perform," or (2) "[s]ignificantly restricted as to the condition, manner, or duration under which [he] can perform a particular major life activity as compared to the condition, manner, or duration under which the average person in the general population can perform that same major life activity."10

Specifically, the term "substantially limits" is defined as "significantly restrict[s] the ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person having comparable training, skills and abilities."" Furthermore, EEOC regulations state that "[t]he inability to perform a single, particular job does not constitute a substantial limitation in the major life activity of working."12

Lower court rulings

The district court granted Toyota's motion for summary judgment, holding that Williams was not substantially limited in any major life activity and therefore did not have a "disability" within the meaning of 42 U.S.C. (sec) 12102(2)(A).13

Focusing its analysis on Ella Williams's ability to perform work-related tasks, the U.S. Court of Appeals for the Sixth Circuit reversed the district court's grant of summary judgment for the defendant. The court of appeals cited EEOC regulations that specifically address limitations on the "major life activity" of "working" and the Supreme Court's discussion of that regulation in Sutton v. United Air Lines, Inc.14 for the proposition that an individual must be precluded from a "substantial class of jobs" to establish disability based on the major life activity of "working." Applying this "substantial class" analysis, the court concluded that Williams's injuries to her arms, shoulders, and neck were sufficiently disabling to permit a factfinder to place her among the protected class of individuals who must be given reasonable accommodation under the ADA.15 The court noted, however, that, on remand, Toyota would have the opportunity to raise an affirmative defense as to why it was not able to accommodate Williams.16

In a dissent from the court of appeals' decision, Judge Boggs noted that although Williams's physical impairment prevented her from performing tasks associated with a discrete range of jobs, "this inability to perform certain types of tasks would not likely constitute being disabled with regard to the major life activity of working."17 In his view and that of the petitioner, Williams was not disabled with regard to the major life activity of performing manual tasks, since the record indicated that her inability to perform those specific tasks was limited to a narrow range of jobs. Thus, her ability to perform various work-related manual tasks, in addition to "brushing her teeth, laundering her clothes, and doing some driving," prevented her from being substantially limited with respect to the major life activity of performing manual tasks.18

Supreme Court to weigh in

With this decision, the U.S. Supreme Court will have a chance to broaden or limit the scope of ADA coverage. Are the phrases "substantially limited" and "major life activity" intended to reflect broad coverage? Or is the ADA intended to cover only a confined and historically disadvantaged class of discrete and insular minorities? In answering these questions, the Supreme Court will have a chance not only to clarify its previous rulings, but also the role of the EEOC regulations.

Iris Lan