The Supreme Court: Determining Who Is Disabled Under the ADA

Determining Who Is Disabled Under the ADA

Ever since the ADA was passed, the Supreme Court rulings have limited aspects of that law and the impact it has on both states and businesses. One such case is Toyota Motor Mfg. v. Williams decided on January 8, 2002.

Ella Williams developed carpal tunnel syndrome in her upper extremities. This condition involves painful muscle and tendon injuries that resulted from highly repetitive motions, such as would be required on a Toyota assembly line. Toyota reassigned Williams to other positions, which worked for three years, but then Toyota added some task that reawakened the pain of carpal tunnel syndrome. Williams and Toyota disagreed about what happened next, but ultimately Williams was fired.

The district court ruled that Williams was not disabled because carpal tunnel syndrome had not substantially limited any major life activity and said there was not evidence that Williams had a record of “substantially limiting impairment.” The 6th Circuit Court reversed that decision because it found that Williams had demonstrated that her manual disability involved a class of manual activities that did affect her ability to perform tasks at work so some accommodation should have been made. The Supreme Court unanimously reversed the circuit court, finding that an impairment must be permanent or long-term.

In writing the opinion of the Court, Justice O'Connor ruled:

• “Given the large potential differences in the severity and duration of carpal tunnel syndrome, an individual's carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA.”

Keeping things equal can be a difficult balance that frequently pits the Congress against the Court. Next we'll explore the issues of freedom guaranteed by the First Amendment.