In addition, the impairments impact must be permanent or long-term.

“It is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment,” the court said. “Instead, the ADA requires them to offer evidence that the extent of the limitation caused by their impairment in terms of their own experience is substantial.”

Patrick Clearly, senior vice president with the Washington-based National Association of Manufacturers, praised the courts ruling.

“Todays Supreme Court ruling makes it clear that the ADA is still the Americans with Disabilities Act, not the Americans with Injuries Act,” he said. “We are gratified that the Courts quick and unanimous decision validates our position that the original intent of the ADA should be preserved without diluting its focus on helping the disabled succeed in the workplace.”

The decisionin the case of Toyota Motor v. Williamsinvolves a Toyota factory worker named Ella Williams, who claimed that she had several impairments, including carpal tunnel syndrome, that substantially limited her ability to perform certain manual tasks on an assembly line. Ms. Williams asked Toyota to accommodate her medical condition by allowing her to perform only certain tasks on the assembly line.

The parties are in dispute over what happened next. Ms. Williams claimed that Toyota refused her request and forced her to continue performing tasks that caused her even greater physical injury. Toyota claimed that Ms. Williams began missing work regularly, and she was terminated due to a poor attendance record.

Ms. Williams filed a complaint with the U.S. Equal Employment Opportunities Commission and received a “right to sue” letter. She then filed suit against Toyota claiming the company violated the ADA by refusing to make a reasonable accommodation and terminating her employment.

The U.S. District Court for the Eastern District of Kentucky granted a summary judgment that Ms. Williams was not disabled under the terms of ADA. While she did have a physical impairment, the court said, Ms. Williams was not substantially limited in any major life activity.

The court added that Ms. Williams did not submit sufficient evidence to demonstrate that she was substantially limited in lifting or working.

The Sixth Circuit Court of Appeals reversed the district court. The Sixth Circuit ruled that in order to show that she was disabled, Ms. Williams need only demonstrate that “her manual disability involved a class of manual activities affecting the ability to perform tasks at work.”

The Sixth Circuit said the fact that Ms. Williams could tend to her own personal hygiene and carry out personal chores is immaterial, since such evidence does not affect a determination that she was substantially limited at work.

But in an opinion written by Justice Sandra Day OConnor, the Supreme Court said unanimously that “merely having an impairment does not make one disabled for the purposes of ADA.”

The Sixth Circuit erred, the Supreme Court said, because it analyzed only a limited class of manual tasks and did not ask whether Ms. Williams impairments prevented or restricted her from performing tasks that are of central importance to most peoples daily lives.

Reproduced from National Underwriter Property & Casualty/Risk & Benefits Management Edition, January 14, 2002. Copyright 2002 by The National Underwriter Company in the serial publication. All rights reserved.Copyright in this article as an independent work may be held by the author.

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