In a case that has some impact on California employers, the United States Supreme Court, addressing the Americans with Disabilities Act (ADA), considered the issue of what a plaintiff must show to establish a substantial limitation on the major life activity of performing manual tasks. [Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, ___ U.S. ___, 122 S. Ct. 681 (2002.]
Plaintiff worked for Defendant at one of its automobile manufacturing plants. During her tenure of employment, Plaintiff was diagnosed with carpal tunnel syndrome and several other related conditions. Plaintiff’s medical problems caused her physicians to place on her significant work restrictions regarding lifting, repetitive motion, overhead work, and use of vibratory tools. After accommodating these restrictions for some time, Defendant assigned certain tasks to Plaintiff that she claimed she could not perform without significant pain. Defendant refused Plaintiff’s request to accommodate her disability by allowing her to return to doing the jobs that did not cause pain.
After being terminated from her employment, Plaintiff sued Defendant under the ADA, alleging that her physical impairments substantially limited the major life activity of performing manual tasks. The United States Supreme Court agreed to review Plaintiff’s case “to consider the proper standard [under the ADA] for assessing whether an individual is limited in performing manual tasks.” (Although Plaintiff also claimed substantial limitation in her ability to work and to lift, the Supreme Court, for procedural reasons, did not address these alleged major life activities.)
To qualify as a disabled person under the ADA, a person must show that he or she has an impairment that substantially1 limits a major life activity. The Court made it clear that a plaintiff’s burden is heavy because these terms must be “interpreted strictly to create a demanding standard for qualifying as disabled.” (Emphasis added.) According to the Court, the word substantially means that a person must show more than "minor" interference with the performance of manual tasks. Furthermore, the phrase “major life activities” refers to “those activities that are of central importance to daily life.” Therefore, the Court held that “to be substantially limited in performing manual tasks, an individual must have [a permanent or long-term] impairment that prevents or severely restricts the individual from doing activities that are of central importance to most peoples’ daily lives.”
The Court explained that the central issue is whether the disabled person is “unable to perform the variety of tasks central to most peoples’ daily lives, not whether the claimant is unable to perform tasks associated with her job.” (Emphasis added.) Therefore, tasks associated with the job may have only limited relevance. On the other hand, “household chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to peoples’ daily lives.”
The Court sent the case back to the lower court for further consideration and gave some guidance as to what factors to consider in determining if Plaintiff is substantially limited in the major life activity of performing manual tasks. For instance, although Plaintiff may not perform repetitive work with hands and arms extended at or above shoulder levels for extended periods of time, the Court noted that this type of manual task is not an important part of most peoples’ lives. The Court further noted that Plaintiff is still capable of doing many of the manual tasks required of her original job. As for “tasks central to most peoples’ daily lives,” the Court noted that Plaintiff can “brush her teeth, wash her face, bathe, tend her flower garden, fix breakfast, do laundry, and pick up around the house.” Plaintiff’s ability to do all of these things must be weighed against the fact that Plaintiff’s medical conditions have caused her to avoid sweeping, quit dancing, and occasionally seek help dressing, and have reduced how often she plays with her children, gardens, and drives long distances.
1 California law does not require that a major life activity be impaired substantially. See California’s Fair Employment and Housing Act (Gov. Code § 12900 et. seq.).