January 9, 2002 
No. 2002-01

The U.S. Supreme Court issued a major victory for employers this week by narrowing what constitutes a disability under the Americans with Disabilities Act (ADA). Toyota Motor Manufacturing Inc. v. Williams. The Court held that a Toyota employee had not proved that she suffered from a "manual task disability" because of her carpal tunnel condition. 

The Court scrutinized the ADA's definition of disability, that is, having an impairment that substantially limits a major life activity. The ADA covers only individuals with an actual or perceived disability or a record of a disability.

In the disability definition, the Court noted that "substantial" means considerable or to a large degree. Thus, impairments that interfere in a minor way only with the performance of manual tasks do not qualify as disabilities.

The Court then considered the meaning of "major life activity" and concluded that it means of central importance to daily life. 

The Court further held that an ADA plaintiff must offer specific evidence that the impairment causes a substantial limitation on a major life activity. It is insufficient to merely submit evidence of an impairment.

In this case, the plaintiff showed only that her medical condition caused her to avoid sweeping, to quit dancing, to occasionally seek help dressing and to reduce how often she plays with her children, gardens and drives long distances. The Court held that these changes in her life did not amount to such severe restriction in activities that are of central importance to her life to establish a manual task disability as a matter of law. The Court also noted that inability to perform to tasks at work is not sufficient to prove substantial limitation on life activities.

An interesting aside is that the Supreme Court, once again, expressly questioned whether working is a major life activity but deferred that issue without deciding it. The Court also took note of Congress' intent to cover only truly disabled individuals, and not everyone with an injury. 

Our recommendation:

Employers should continue to analyze requests for disability accommodations by first determining whether the employee suffered from a disability and is covered by the ADA. This decision instructs employers how to sharpen their analysis and to do so with greater confidence.

In determining whether an employee has a disability, employers should consider: (1) Is there an impairment? (2) Does that impairment limit one's activities substantially–that is, to a considerable or large degree? (3) Is that limitation on a major life activity–that is, an activity of central importance to one's life? Limitations on work activity alone may not be enough to establish ADA coverage. 

In applying Oregon disability discrimination law, courts will likely follow this decision. Oregon law uses the same definition of disability and contains a provision directing that it be construed "consistent with" federal law. Washington law, however, uses a different definition of disability, and courts have not felt compelled to interpret it consistent with federal law.

Call if you have questions.

Jeff Chicoine jchicoine@nsslaw.com 
Wayne Landsverk wlandsverk@nsslaw.com 
Verne Newcomb newcomb@nsslaw.com 
Jack Schwartz schwartz@nsslaw.com 
Rick S. Pope rpope@nsslaw.com 
Brent H. Hall bhall@nsslaw.com 
Thomas Bahrman tbahrman@nsslaw.com

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