ABSTRACT
FACTS: Ella Williams worked in the Toyota motor manufacturing plant in Georgetown, Kentucky. When she began, she was placed on an engine fabrication assembly line where her duties included using pneumatic tools. Eventually, the use of these tools caused pain in her hands, wrists, and arms. She was diagnosed with bilateral carpal tunnel syndrome and bilateral tendinitis. Her doctor advised her not to lift objects more than 20 pounds or to do constant repetitive extensions of her wrists or elbows. Despite her employer’s efforts to accommodate her, Williams felt that her employer was not accommodating her sufficiently. She sued her employer under the Americans with Disabilities Act (ADA), claiming that she was “disabled” under the definition of the Act. The ADA requires employers to provide “reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability” unless the employer can “demonstrate that the accommodation would impose an undue hardship” 42 U.S.C. § 12112(b)(5)(A). Eventually, her case was reviewed by the United States Supreme Court. ISSUE: What standard should a court apply in deciding whether or not a person is “disabled” under the definition of the Americans with Disabilities Act? DECISION: To be “substantially limited” and therefore “disabled” under the definition of the Americans with Disabilities Act, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives. The impairment’s impact must also be permanent or long term. REASONING: The Supreme Court held that a “disability” is a physical or mental impairment that substantially limits one or more major life activities and that has been documented. Merely having an impairment does not make a person disabled for purposes of the ADA. The limitation must be “substantial,” that is, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives, and the impairment’s impact must be permanent or long term. It is insufficient to prove disability by merely submitting evidence of a medical diagnosis because each disability will have a different effect on each individual. Furthermore, manual tasks that are unique to a person’s particular job may not necessarily be relevant to most people’s lives. The court therefore remanded the case back to the lower court to be decided in accordance with this new guidance. IMPLICATIONS: In 1990, on the south lawn of the White House, with 3,000 disability rights advocates, members of Congress, and the administration looking on, President George Bush, Sr., signed the Americans with Disabilities Act into law. He described the
ADA as “the world’s first comprehensive declaration of the equality of people with disabilities, and evidence of America’s leadership internationally in the cause of human rights.” Under the ADA, an individual with a disability is a person who (1) has a physical or mental impairment that substantially limits one or more major life activities; (2) has a record of such an impairment; or (3) is regarded as having such an impairment. The ADA does not list all diseases or conditions that make up “physical or mental impairment.” “Stress” and “depression” are conditions that may be considered impairments, but their very existence does not make a person “disabled.” The ADA prohibits discrimination against qualified individuals with disabilities in public and private sector employment. This includes a requirement that those employers covered under the Act make reasonable accommodations to the known physical or mental limitations of qualified applicants and employees, unless providing such accommodations would impose an undue hardship on the employer.
