The Supreme Court's Answer: It Depends !

In a widely publicized case, the Supreme Court recently held that a woman with carpal tunnel syndrome and other conditions was not necessarily disabled under the Americans with Disabilities Act (ADA). Contrary to some news reports, however, the Court didn't decide that carpal tunnel syndrome could never qualify as a disability. Instead, it clarified what an employee must show to demonstrate that she is disabled - and emphasized that courts must decide whether someone is disabled on a case-by-case basis.

The Facts: Toyota Motor Manufacturing v. Williams

Ella Williams worked on the Quality Control Inspections Operations (QCIO) team at Toyota Motor Manufacturing in Kentucky, checking the shell and paint on cars passing on a conveyor. Williams had previously been diagnosed with bilateral carpal tunnel syndrome and tendonitis while working on an engine assembly line. Initially, her work on the QCIO team included only two tasks, which she was able to perform.

But when additional tasks were added that required her to hold her hand and arms at shoulder height for several hours at a time, Williams developed additional problems, including myotendinitis bilateral periscapular, myotendinitis bilateral forearms and thoracic outlet compression, all of which caused her pain in the neck and shoulders. Williams asked Toyota to let her go back to doing the two tasks that didn't cause her pain. Toyota refused, and Williams was eventually fired for poor attendance. Williams then sued Toyota for refusing to accommodate her disability.

Under the ADA, an employee is disabled if she has a physical or mental impairment that substantially limits one or more of her major life activities. Williams argued that she was disabled because her medical conditions substantially limited her ability to perform manual tasks. Although the trial court found that Williams was not disabled, the Court of Appeals for the 6th Circuit overruled that decision, finding that Williams' conditions substantially limited her ability to perform a class of manual activities related to her tasks at work. Toyota then appealed to the Supreme Court.

The Supreme Court's Decision: There's More to Life Than Work

The Supreme Court had to decide what an employee must prove to demonstrate that she is substantially limited in performing manual tasks. The Court found that it is not enough for an employee to show that she cannot perform the manual tasks her job requires: Instead, she must show that her condition prevents or severely restricts her ability to do manual activities that are of central importance to most people's daily lives - like household chores, bathing and brushing their teeth. The Court pointed out that some jobs require unique manual tasks that are not necessarily an important part of most people's lives and to say that people who can't perform these tasks are disabled would expand the reach of the ADA beyond what Congress intended when it passed the law. Because the 6th Circuit only considered the effect of Williams' disability in the workplace, the Supreme Court sent the case back for further proceedings.

What the Case Means for Employees

There are two important lessons here for employees with carpal tunnel syndrome - or for any employee seeking to prove that she is disabled. First, having a particular impairment or condition, whether it is carpal tunnel syndrome, lupus or AIDS, does not necessarily mean that you are disabled under the law. You must show that you suffer a substantial limitation in a major life activity to be protected under the ADA. As the Supreme Court noted, the severity of a particular condition may vary from person to person: one quarter of carpal tunnel syndrome cases resolve in a month, while almost the same number of cases persist for eight years or longer. It is not enough to rely on a diagnosis: Employees seeking the ADA's protection must demonstrate that they, personally, have suffered substantial limitations resulting from their condition.

Second, you must focus on limitations in practical, daily-life activities when trying to prove a disability. For many employees, this won't make it harder to prove they are disabled, although it will require a different type of evidence. Many workers with repetitive stress disorders suffer a number of limitations in their daily lives, from problems dressing or grooming themselves to difficulties holding their children and trouble doing household chores. Instead of proving difficulties with key strokes or overhead work, these employees with repetitive strain disorders will have to focus on the stuff of everyday life to prove that they are disabled.