High court narrows meaning of disability

To qualify under law requires limit on acts `central to daily life'

January 09, 2002|By NEW YORK TIMES NEWS SERVICE

WASHINGTON - The Supreme Court ruled yesterday that to qualify as disabled and be protected by the Americans With Disabilities Act, a person must have substantial limitations on abilities that are "central to daily life," not to life in the workplace only.

The unanimous ruling was the latest and one of the most important in a series of Supreme Court decisions that have interpreted and, for the most part, narrowed the broad terms of the 1990 law, which obligates employers to make reasonable accommodations for disabled workers.

As a result of the increasingly stringent definitions of disability, plaintiffs are finding it much more difficult than the law's advocates expected to win their cases, or even to get into court in the first place.

Employers viewed the opinion yesterday, by Justice Sandra Day O'Connor, as a significant victory. It overturned a lower federal court's finding that an assembly line worker at a Toyota plant who suffered from carpal tunnel syndrome, an ailment involving muscle and tendon injuries from repetitive activities, was disabled in the "major life activity of performing manual tasks."

The justices' ruling was not conclusive, leaving open the possibility that the woman, Ella Williams, who worked for six years at the Toyota plant in Georgetown, Ky., might still win her case when it goes back to the U.S. 6th Circuit Court of Appeals in Cincinnati.

The appeals court had granted summary judgment to Williams, finding her disabled as a matter of law based on her inability to meet the demands of her assembly line job and of other jobs that require gripping tools and working with arms elevated and outstretched.

That was too narrow a focus on which to base a finding of disability, O'Connor said, because it ignored the question of whether the limitations affected Williams' daily life outside the factory.

"The central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives," not just those associated with a particular job, O'Connor said, adding that "household chores, bathing and brushing one's teeth are among the types of manual tasks of central importance to people's daily lives" and should have been part of the court's inquiry.

The repetitive work that caused the problem for Williams "is not an important part of most people's daily lives," O'Connor said.

Williams had testified that though she needed help dressing and had given up such activities as sweeping and dancing, she could still take care of personal hygiene, cook and perform some housework and gardening.

But the appeals court disregarded the non-workplace evidence. Without an evaluation of the full effect of Williams' impairment, summary judgment in her favor was inappropriate, O'Connor said.

"These changes in her life did not amount to such severe restrictions in the activities that are of central importance to most people's daily lives that they establish a manual-task disability as a matter of law," the opinion said.

Although Williams is unlikely to win in the lower court, the decision could help plaintiffs whose limitations have more effect outside the workplace than within it, said Chai Feldblum of the Georgetown University Law Center.

"If brushing your teeth qualifies as an essential activity, then so do other things like taking out the garbage" or lifting things around the house, Feldblum, an authority on the statute, said in an interview.

Nonetheless, she said, the court's approach yesterday is likely to pose new problems for some plaintiffs, many of whom have been shut out of court by the Supreme Court's previous rulings and by lower courts' responses to those rulings.

In three decisions in 1999, the Supreme Court considered whether people qualified as disabled if their conditions could be corrected or kept in check by medication or by devices like eyeglasses. Corrective measures must be taken into account in assessing disability, the court ruled. Feldblum said lower courts had interpreted the 1999 decisions to hold that people with diabetes, epilepsy, prosthetic limbs and schizophrenia were not disabled.

Stephen Bokat, executive vice president of the National Chamber Litigation Center, the legal arm of the U.S. Chamber of Commerce, called the decision a significant victory for employers.

"The court understood," Bokat said, "that the ADA was not meant to create a loophole for people with routine limitations or minor injuries, but was intended for people with significant limitations."

After Williams, who is now 42, developed her repetitive motion injury, Toyota at first accommodated her by assigning her to inspect the paint on finished cars as they moved along a conveyor belt at the rate of one per minute. That job involved minimal use of her arms.

But then Toyota required her to use a sponge to wipe oil on the cars. Her physical problems returned. When Toyota refused to change her assignment, she stopped going to work. The company dismissed her, and she sued.

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