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Straight
Track #96
| Supreme Court Raises Bar For The Disabled Robert J. Drummond
Hoey & Farina Attorney
1-888-425-1212
Ella Williams, like many workers who perform stressful repetitive tasks, developed bilateral carpal tunnel syndrome and tendonitis in the course of her employment. |
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Unlike the vast majority of workers who sustain injury in the course of their employment, her name will be preserved in legal history in one of the few cases to reach the United States Supreme Court. Toyota v. Williams, decided January 8, 2002, is the most recent decision of the Supreme Court, and perhaps the most significant, interpreting our rights under the Americans with Disabilities Act (ADA). Although this case did not involve a railroad, the decision applies to all employers and employees, including rail carriers. The Court addressed the very significant question of how to determine whether a person suffers from a “disability” under the Act “in performing manual tasks.”
By way of background, Ms. Williams and Toyota had been involved in litigation over her medical and work activities prior to her landmark lawsuit. She began working for Toyota in August, 1990, and was soon placed on the engine fabrication assembly line which required her to work with pneumatic tools. The repetitive use of these tools eventually caused pain in her hands, wrists and arms. She first sought treatment with the company doctor, who diagnosed her with bilateral carpal tunnel syndrome and tendonitis. Her personal physician placed her on permanent work restrictions that precluded her “from lifting more than 20 pounds; from frequently carrying objects up to 10 pounds; from repetitive extension or flexion of her wrists or elbows; and from performing overhead work or using vibratory or pneumatic tools.” Toyota then assigned her to various modified duty jobs.
Ms. Williams continued to lose time in the modified duty jobs, and was not satisfied with Toyota’s attempts to accommodate her work restrictions. Prior to the case which is the subject of this article, she filed a Workers’ Compensation Claim and her first case under the ADA. Both of these cases were settled, and as part of the ADA settlement she returned to work in 1993.
When she returned to work she was assigned to the Quality Control section of the plant. This group was responsible for performing four separate quality control tasks. Ms. Williams’s was able to perform two of these tasks for approximately three years. In the fall of 1996, Toyota required the Quality Control inspectors, including Ms. Williams, to rotate through all four tasks. The new tasks violated her medical restrictions. She began to experience additional medical problems, and an aggravation of her prior condition. She asked that she be allowed to return to her prior tasks, and not rotate through all four positions. She contended that this request was refused. Her last day of work was in December, 1996. She then filed her second case under the ADA.
To be eligible under the ADA, a person must suffer from a “disability that substantially limits a major life activity.” Major life activities under the Act include: caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. A “disability” may be a medical condition involving any of the above activities, but the limiting effect must be “substantial.”
Ms. Williams claimed that she was “disabled” under the ADA in that her physical impairments, which were not contested, substantially limited her in: “1.) manual tasks; 2.) housework; 3.) gardening; 4.) playing with her children; 5.) lifting; and 6.) working.” All of these activities, she contended, were major life activities under the Act. The issue in Ms. Williams’s claim became whether she was “disabled” from a physical impairment that “substantially limited” any “major life activity.” These terms have ordinary meanings which we are all familiar with. The courts, however, are constrained to address these terms within the context of the statute itself, and the regulations passed to enforce the statute.
The trial court found that she suffered from an impairment but that it did not substantially limit any major life activity. With respect to her non-work activities, the court refused to consider these in the analysis. With respect to her work activities, the court found that her ability to do some of the manual tasks assigned negated her claim that she was substantially limited. Toyota was granted judgment in its favor.
The Appellate Court reversed the trial court, and entered judgment in favor of Ms. Williams. The Appellate Court held that she had sufficiently demonstrated that she was “disabled due to a substantial limitation in the ability to perform manual tasks” at work. This court also disregarded the evidence that she had presented regarding her inability to perform non-work related activities such as personal hygiene and household chores. The Appellate Court found that Ms. Williams established her case that she was “substantially limited in her ability to perform the range of tasks associated with an assembly line job.”
The U.S. Supreme Court then took the case. It formulated the inquiry as to what a person “must demonstrate to establish a substantial limitation in the specific major life activity of performing manual tasks.” Curiously, the court did not address her claim that she was limited in her ability to work. The court held that when addressing the major life activity of performing manual tasks, “the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most peoples’ daily lives, not whether the claimant is unable to perform the tasks associated with a specific job.” In contrast to the Appellate Court, the court found that the specific requirements of a particular job may have only limited relevance to this manual task inquiry. The court then reversed the judgment in favor of Ms. Williams, and sent the case back to the Appellate Court to reconsider the facts in light of this opinion.
Our common understanding of the ADA is that it was enacted to address disabilities which were encountered in the work place, and not in the home. The Supreme Court has held, however, that we must focus on our major life activities, away from work, to determine whether we are eligible to present a claim of work place disability. Thus, not only does a person need to establish difficulty in performing their tasks assigned at work, they now must establish the limitations that they encounter away from the work place. For example, if a disability in performing manual tasks is to be considered under the Act, difficulty in dressing one’s self, bathing one’s self, and performing household chores, are now relevant to the inquiry. Not only are they relevant, they are required if you are to establish a substantial limitation.
For example, if you suffer from bilateral carpal tunnel syndrome, the fact that you need assistance to button your clothes, cut your food, tie your shoes, or grasp a toothbrush, now becomes relevant. The court’s opinion also seems to invite evidence that in addition to your specific job requirements, you are disabled from many jobs which require manual dexterity in performing the work. This type of analysis will require the testimony of a vocational disability expert. Such an expert, however, is well versed in translating non-work related physical limitations into work place limitations.
Ms. Williams’s plight is uncertain at this point. Her case has been sent back to the Appellate Court for reconsideration of the evidence of her non-work related disabilities. Whether she has presented enough evidence under this standard is yet to be determined. To be sure, the Supreme Court has raised the threshold requirements for presenting a claim under the ADA. These requirements, however, are part of the statute which Congress almost unanimously passed into law. Successful presentation of these claims requires a new focus on the evidence establishing your disability. Further refinements of the law, may require that Congress be more specific in establishing who is qualified under the Act.
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