Toyota Motor Manufacturing, Kentucky, Inc. v. Williams: The Supreme Court's ADA Carpal Tunnel Decision - What it Means for Employers
In a unanimous decision issued on January 8, 2002 the U.S. Supreme Court narrowed the scope of the Americans With Disabilities Act (the ADA), ruling that to qualify as a disability covered by the ADA, an impairment such as carpal tunnel syndrome must have a “substantial effect” on an employee’s daily life, not just that person’s ability to perform his or her specific job.
It has long been held that an impairment alone is not a disability under the ADA, but the Court has now made it clear that a condition that merely affects one’s ability to perform a specific job-related task, or set of tasks, is not a disability either. Considering the controversy over whether carpal tunnel syndrome and other asserted repetitive-stress injuries trigger accommodation requirements for employers, this decision is very significant.
The Lower Court Rulings
The plaintiff was an assembly-line worker at a Toyota automotive plant in Kentucky who developed carpal tunnel syndrome. She asserted that her ability to perform her job was impaired as a result. Toyota placed her in a job that she could perform without pain or impairment. Unfortunately for the plaintiff, however, the job duties of her new position were expanded to include other manual tasks that apparently caused her to suffer an injury similar to her prior injury. The added tasks included applying highlight oil to each car on the assembly line at a rate of one car per minute. According to her medical diagnosis, the plaintiff was unable to perform these new manual tasks, and she requested that Toyota accommodate her by scaling her duties back to what they were prior to the expansion of her job.
When Toyota refused to provide the requested accommodation, the plaintiff filed a claim against the company under the ADA. The federal trial court dismissed her case in 1997, but the U.S. Court of Appeals for the Sixth Circuit reversed the dismissal on appeal, ruling that her condition, which rendered her unable to perform the required manual tasks, constituted a disability under the ADA. In reaching this conclusion, the Sixth Circuit ignored and treated as irrelevant evidence that the plaintiff could perform other non-work-related manual tasks (such as tending to her personal hygiene and carrying out household chores). The Sixth Circuit found it sufficient that she could not perform the manual work required by her job.
The Supreme Court’s Decision
On review, the Supreme Court reversed the Sixth Circuit’s ruling. Justice Sandra Day O’Connor, writing for a unanimous Court, held that the Sixth Circuit “should not have considered [plaintiff’s] inability to do such manual work in her specialized assembly line job as sufficient proof that she was substantially limited in performing manual tasks.” The Court held that for an impairment to be a legally recognized disability under the ADA, the plaintiff must be unable to perform a class of manual tasks that “are of central importance to people’s daily lives.” The Court thus found that the lower court erred in ignoring the plaintiff’s ability to perform other non-work-related manual tasks.
In reaching its decision, the Supreme Court relied on the basic dictionary definitions of the terms used in the ADA. The ADA defines a covered disability as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual.” The Court focused on the word “major,” which means “important.” The Court recognized that “performing manual tasks” is a major (or important) life activity covered by the ADA, and further stated that such “major life activities” are those that are “central to daily life.” Thus, the issue before the Court in Toyota was: “what [must] a plaintiff [ ] demonstrate to establish a substantial limitation in the specific major life activity of performing manual tasks.”
The primary question, according to Justice O’Connor, was whether the employee was “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.” Household chores, bathing, and brushing teeth are among this category of manual tasks cited by the Court as being of central importance to daily life. The plaintiff in Toyota admitted that she could perform these manual tasks without impairment. For this reason, the Supreme Court remanded the case to the Sixth Circuit for further consideration in light of the Supreme Court’s opinion.
Practical Impact of the Decision
It is important to note that the Supreme Court did not rule on whether the plaintiff in Toyota was disabled. It also did not hold that carpal tunnel syndrome, or other asserted repetitive stress injuries, cannot be the basis of a valid ADA claim. The Court merely held that the Sixth Circuit applied the wrong standard and ignored evidence relevant to the issue when deciding that the plaintiff was disabled.
The effect of the decision is to give employers more options when faced with employee requests for accommodations under the ADA based on asserted impairments that involve limitations of their ability to perform manual tasks. It is clear, however, that the Supreme Court’s decision does not provide employers with a “bright line” test for determining when a valid ADA claim has been made. Significant issues of judgment will remain. Thus, employers now may require such employees to show that they are limited in more than just their ability to perform certain tasks required by their jobs in order to qualify for an accommodation. This will involve an inquiry into the employee’s ability to perform daily tasks. Employers will need to decide, however, what proof of impairment in the performance of such tasks will be required, and how much impairment is sufficient to trigger an accommodation requirement.
It is also important to understand that the Supreme Court’s decision relates only to the ADA. It does not affect whether conditions such as carpal tunnel syndrome will be recognized by state workers’ compensation agencies as compensable injuries, and whether employers must respect a physician’s direction that an employee be given time off from work, or be given light duty assignments.
The decision also has no effect on an employer’s obligations under the federal (and where applicable, any state) occupational safety and health requirements. There is no federal OSHA ergonomics standard, and none is likely to be proposed in the near future. In theory, under the OSHA so-called “general duty clause,” employers are required to keep their workplaces free of “ergonomic” hazards, but in the current political climate, it is seen as unlikely that OSHA will pursue ergonomics citations under the general duty clause.
The Toyota decision allows employers to give greater scrutiny to requests for accommodations under the ADA. Significant questions of judgment remain, however, and it is reasonable to expect that future claims will test the limits and impact of the Supreme Court’s recent decision. If you are interested in learning more about this issue, or would like assistance in dealing with these matters, please contact us. Arent Fox regularly handles employment matters for its clients, including those arising under the ADA and OSHA, and we stand ready to assist you with your needs.