Supreme Court Rules Substantial Life Impact Required for ADA Claims

Posted: January 28, 2002

The Supreme Court has handed down another decision defining the scope of the definition of disability under the Americans with Disabilities Act. Under the ADA, an individual must have a physical or mental impairment that substantially limits one or more major life activities in order to "qualify" as disabled.

In Toyota v. Williams, by unanimous vote, the Court held that it is not enough for someone to be severely limited in her ability to perform an activity in the workplace; he or she must be severely limited or completely unable to participate in a major life activity outside the workplace as well.

Since the spring of 1998, when the Supreme Court decided in Sutton v. United Airlines et al. that in determining whether an individual has a disability under the ADA, a court must consider the effects of any measures that reduce the effect of the disability - like medicine or glasses - it has become increasingly difficult for people with epilepsy to persuade the courts that they have disabilities and are entitled to the law's protections.

In this case, a woman with carpal tunnel syndrome sued her employer, an auto manufacturer, under the ADA for discrimination on the basis of disability. The employer defended in part on the ground that she was not disabled under the ADA. Williams claimed she was disabled because she had a physical impairment that substantially limited her ability to perform manual tasks in the workplace; however, she could perform a wide range of manual tasks, such as brushing her teeth, sweeping, and gardening, outside of the workplace.

The Supreme Court's decision reverses a lower court ruling in Williams' favor, saying that it applied an inappropriate standard for determining whether she had a disability by focusing on the impact of the disability in the workplace rather than in activities of daily living. The case now goes back to the lower court to determine whether Williams' carpal tunnel syndrome impacts her daily living activities.

The Supreme Court said that it "refers to those activities that are of central importance to daily life." The court further explained that an individual is substantially limited in a major life activity even if the impact of her condition on a single activity is not severe as long as her ability to perform a variety of activities collectively is severely limited.

The Foundation will continue to report on current cases involving people with epilepsy on its On the Docket feature of the website.