Justices Say Toyota Need Not Assist Worker
Bob Egelko, Chronicle Staff Writer
Published 4:00 am, Wednesday, January 9, 2002
Further limiting federal workplace protections for the disabled, the U. S. Supreme Court ruled yesterday that an assembly-line worker with carpal tunnel syndrome had not shown she was entitled to accommodations on the job.
The unanimous decision makes the federal law less worker friendly, especially when compared to California’s more liberal disability law.
It is the second time in three years that the nation’s high court has narrowed the definition of disabled workers — those entitled to accommodations from their employers allowing them to stay on the job. It is also the third time in that period that the justices have restricted the right to sue under the 1990 Americans with Disabilities Act.
In yesterday’s ruling, the court said a worker was not “disabled” merely because pain and mobility limitations in her wrists, arms and hands prevented her from doing her job on a Toyota assembly line. She must also show that she suffers severe limits in everyday activities outside work.
“The manual tasks unique to any particular job are not necessarily important parts of most people’s lives,” wrote Justice Sandra Day O’Connor. If an inability to perform manual tasks qualifies as a disability, she said, it must affect “the variety of tasks central to most people’s daily lives,” such as “household chores, bathing and brushing one’s teeth.”
The ruling follows a set of decisions in 1999 that refused to classify conditions such as impaired vision and high blood pressure as disabilities if they could be remedied by medication or treatment.
Referring to those decisions, O’Connor said yesterday that the ADA’s definition of disability — an impairment that substantially limits a “major life activity” — must be “interpreted strictly to create a demanding standard.”
Last year, the court ruled that state governments were protected from damage suits under the ADA if they discriminated against disabled employees.
Millions of Americans suffer from carpal tunnel syndrome or related ailments caused by repetitive movements on assembly lines or at computer keyboards. Their ADA claims will be harder to prove, though not necessarily impossible in severe cases, as a result of yesterday’s ruling.
The court’s subtext — that it sees itself as the “gatekeeper” for ADA cases — may be more important than the details of the ruling, said Arlene Mayerson, directing attorney of the Disability Rights Education and Defense Fund in Berkeley. “It sends yet another signal that the class of people (covered by the law) is a narrow one,” and underscores the greater protections provided by California law, she said.
California law defines disabilities more broadly, specifies that an impairment that prevents a worker from performing a job is a disability, and covers workers with conditions that could be remedied. The law also allows damage suits by state employees and permits unlimited damages, in contrast to the ADA’s maximum of $300,000 plus wage losses.
“This continues to spell the difference between the business environment in other states and California,” said San Francisco attorney Patricia Gillette, who represents employers.
Yesterday’s ruling involved Ella Williams, whose pain from carpal tunnel syndrome and tendinitis left her unable to lift tools on her assembly-line job at a Toyota plant in Georgetown, Ky. Her pain eased when she was transferred to an inspection job, but returned when the job duties were expanded. She sued after the company refused to return her to the previous job.
A federal appeals court in Cincinnati ruled that Williams was disabled because of her inability to do her job. The Supreme Court disagreed. The case is Toyota vs. Williams, 00-1089.