Who is a Disabled Employee?
When is a worker considered "disabled" under the Americans With Disabilities Act? The United States Supreme Court helped partially answer that question in its recent decision in Toyota Motor Manufacturing, Inc. v. Williams. The answer was a person must have substantial limitations on abilities that are "central to daily life" and not only to life in the workplace.
In the Toyota case, a lower court had found as a matter of law that Mrs. Williams was disabled because she could not do many of the tasks required of her job because of carpal tunnel syndrome. The Supreme Court said this focus was too narrow and that what should be examined in determining disability was not only what someone could or could not do in the workplace but also how their daily lives were affected. Could the person dress and bathe themselves, brush their teeth, do household chores and do other things central to most people's daily lives?
This most recent decision follows other recent decisions, making it more difficult for workers to prove disability. Lower court decisions have found that persons whose disability can be controlled or corrected by medication, artificial limbs or even eyeglasses may not be disabled. Persons with diabetes, epilepsy, prosthetic limbs and schizophrenia may not be disabled under these recent decisions.
More Americans With Disabilities Act cases are before the United States Supreme Court this term. Some of the issues to be decided are whether employers must accommodate the needs of disabled workers even if the accommodation overrides the seniority rights of other workers, and whether an employer can refuse to hire someone whose disability would make the job a threat to his own health or life.