Supreme Court Limits Scope of ADA The Supreme Court recently limited the scope of the Americans with Disabilities Act (ADA) by narrowing the definition of disability to a substantial limitation on abilities that are central to everyday life and not to specific job-related tasks. The Supreme Court’s unanimous ruling is the latest and most important in ... Policy Analysis
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Policy Analysis  |   February 01, 2002
Supreme Court Limits Scope of ADA
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Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   February 01, 2002
Supreme Court Limits Scope of ADA
The ASHA Leader, February 2002, Vol. 7, 1-15. doi:10.1044/leader.PA2.07032002.1
The ASHA Leader, February 2002, Vol. 7, 1-15. doi:10.1044/leader.PA2.07032002.1
The Supreme Court recently limited the scope of the Americans with Disabilities Act (ADA) by narrowing the definition of disability to a substantial limitation on abilities that are central to everyday life and not to specific job-related tasks.
The Supreme Court’s unanimous ruling is the latest and most important in a series of decisions that have steadily narrowed the interpretation of the sweeping 1990 civil rights law. “Disability rights advocates responded to this ruling as a setback,” noted Karen Beverly-Ducker, ASHA’s director of multicultural resources. “It will present a major obstacle to some individuals with disabilities who want to work, and can do so, but need accommodations by the employer.”
“Justice Sandra Day O’Connor’s comments in this case, and those made by justices in related rulings, raise questions about the Court’s sensitivity to and understanding of issues related to disability rights,” Beverly-Ducker said.
The decision overturned a federal court ruling that an assembly-line worker, Ella Williams, who has carpal tunnel syndrome, was disabled in the “major life activity of performing manual tasks.”
Williams, who worked for six years at the Toyota Motor Corp. assembly plant in Georgetown, KY, developed carpal tunnel syndrome, a repetitive-stress injury that caused pain to her arms and hands and left her unable to perform the essential functions of her job that require gripping tools and working with arms elevated and outstretched. Toyota accommodated Williams by transferring her to another job at the plant that involved inspecting paint on cars. Later, this job was expanded to include wiping cars as they passed on the assembly line. Williams sued when her job was not restructured to the more limited tasks she had been performing, saying that her injuries prevented her from performing the expanded job duties.
In her opinion, Justice Sandra Day O’Connor found the appeals court’s focus on Williams’ job too narrow in determining that she was disabled under the ADA because it analyzed only a limited class of manual tasks. Instead, O’Connor said, “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.” In this case, Williams was able to perform manual tasks that are important to daily life—such as household chores, bathing, and brushing one’s teeth—but was unable to perform job-specific tasks that involved repetitive motion.
O’Connor also stressed that there is a need for a case-by-case determination of disability rather than a conclusion based on medical diagnosis, stating that an “individualized assessment of the effect of an impairment is particularly necessary when the impairment is one in which symptoms vary widely from person to person.”
The decision provides a new interpretation of the term “disability,” Beverly-Ducker said. “Although there has never been a laundry list of disabilities that are covered under the ADA, the Supreme Court has ruled that disabilities must be assessed by looking at the variety of tasks that are important to most people’s daily lives, and not just job-specific tasks.”
For those with communication disorders, the impact of the ruling may not be as harsh. The ADA lists communication-related functions—speaking, hearing, and learning—as major life activities. “The difficulty is how and when to identify an individual as having a speech, language, or hearing disability,” Beverly-Ducker said. “While it is fairly easy to identify the presence of a disorder or loss based on test results, the persistent questions of impact and who and how to appropriately label as disabled are still here.”
While the Supreme Court set a new standard for deciding Williams’ claims, it did not rule on the merits of her case, but sent it back to the U.S. Court of Appeals for the Sixth Circuit in Cincinnati where Williams may still win her case.
The ruling comes on the heels of three 1999 Supreme Court rulings that have steadily limited the scope of the ADA. These decisions considered whether people qualified as disabled if their conditions could be corrected or controlled by medication or devices like eyeglasses. The Court ruled that corrective measures must be taken into account in assessing disability.
For more information about the ADA, visit the U.S. Department of Justice’s ADA Web site at http://www.usdoj.gov/crt/ada/adahom1.htmor call the ADA Information Line at 800-514-0301 or 800-514-0383 (TDD).
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February 2002
Volume 7, Issue 3