SCOTUS Curbs the ADA

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The Toyota plant in Georgetown, KY, where Ella Williams worked

Just how broad is the Americans with Disabilities Act? Not as broad as you might think. The U.S. Supreme Court ruled Tuesday that a company is not required to make accommodations for an employee with a specific, disabling condition that prevents her from completing her assigned work — but doesn't keep her from participating in non work-related everyday activities.

In a unanimous decision, the court said that Toyota Motor Corp. did not violate the Americans with Disabilities Act when it fired Ella Williams for poor attendance after Williams' carpal tunnel syndrome kept her from working. Williams' suit against Toyota claimed the company did very little to accommodate her disability — "reasonable accommodations" being a requirement under the ADA. In fact, the Court ruled, Toyota was not required to treat Williams under the guidelines of the ADA, because her condition does not qualify her as disabled. She is, the Court reasoned, still capable of performing "tasks that are of central importance to most people's daily lives," including cleaning her house and gardening.

While the unanimous verdict would seem to indicate severe limitations on future ADA cases, the Court actually warned against such sweeping assumptions, saying each case must be examined on its own merits. "An individualized assessment of the effect of an impairment is particularly necessary when the impairment is one whose symptoms vary widely from person to person," the court said. The door was left firmly ajar for future challenges, as well: the Justices, who sent the case back to a lower court for reconsideration, also declined to rule on whether work is itself considered an "everyday task," and thereby included under the ADA umbrella. (The ADA applies to all workplaces, public and private, with more than 15 employees.)

Some observers theorize, however, that the ruling would affect ADA-related requirements in other public arenas, including transportation and building design — perhaps easing those guidelines to accommodate those who fall under the court's definition of "disabled."

What does the Toyota v. Williams case mean for Americans with disabilities — and for the enforcement of the ADA? spoke with David DuBois, an associate professor of business at SUNY Empire State College in Rochester, NY. Professor DuBois also works with organizations promoting the civil rights of people with disabilities, and is particularly involved in forwarding the profile of adult students with disabilities.

Will this ruling deal a blow to the cause of disability advocates?

Professor Dubois: I'm not sure what precisely the impact of the ruling will be on workers with disabilities — injured workers have at times been affiliated with disability advocates and other times disconnected.

In this case, we're talking about someone who sought protection under the ADA for what appears to be a work-related health problem. This doesn't appear to me to be so much related to the ADA but rather to OSHA. Unfortunately, the Bush administration has narrowed the reach of OSHA — and so now there's really no provisions at all for people with work-related disabilities.

Interestingly, this ruling seems to push us back into the environment where unions and union demands made a real impact on the workplace — we'll have to see where that road takes us.

Do you think this decision will keep employees from stepping forward with allegations of ADA violations?

I do, and I worry about that. For many people, the ramifications of this ruling in terms of work injuries are simply not clear. For people struggling to get a job, which is the case for many people with disabilities, the current job market and the impact of this decision may keep people from talking about their injuries or physical limitations.