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Disabilities

The Court continued its pattern of narrowing the scope of the 1990 Americans with Disabilities Act. Ella Williams, an assembly line worker in Toyota's Lexington, Kentucky, plant, was diagnosed with carpal tunnel syndrome, and was re-assigned to two quality inspection jobs. Toyota then added a third task, and a dispute arose, after which she was fired. Williams claimed that her condition had worsened and the company refused to make an accommodation, while Toyota claimed she began missing work on a frequent basis. Williams filed a letter with the Equal Employment Opportunity Commission, and upon receiving a right-to-sue letter, filed against Toyota in federal district court. The court granted summary judgment to the company on the grounds that Williams did not have a disability as defined by the ADA, and her own testimony indicated that she was not disabled since she claimed she could perform some assembly line work. The Court of Appeals for the Sixth Circuit reversed, on the grounds that Williams had met the ADA test of showing that her manual disability involved a class of work activities that prevented her from doing the tasks to which she had been assigned.

The Supreme Court unanimously reversed, and expanded the relevant test to include not only work-related activities, but the individual must have an impairment that prevents or substantially limits the performance of daily life activities, such a brushing one's teeth, tending a flower garden, or fixing meals. By this test, the definition of an injury or disability that would call the ADA into effect was significantly limited, and it was in line with other decisions of the Court handed down in this term, such as USAirways v. Barnett (2002) (an employer normally does not have to bend its seniority system to make sure a disabled worker can stay on the job); Chevron USA v. Echazabel (an employer can reject a disabled applicant for a job if the work would threaten their health or safety); and Barnes v. Gorman (2002) (individuals successfully suing cities for discrimination under the ADA may only receive compensatory damages and may not sue for punitive damages).

         

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