Supreme Court Rules on ADA Case:

When does a physical impairment substantially limit a major life activity?

The Supreme Court has handed down another decision defining the scope of the definition of disability under the Americans with Disabilities Act (ADA). Under the Americans with Disabilities Act, an individual must have a physical or mental impairment that substantially limits one or more major life activities in order to be disabled. In Toyota v. Williams, by unanimous vote, the Court held that it is not enough for an individual to be severely limited in her ability to perform that activity (in this case performing manual tasks) in the workplace; the individual must be severely limited or completely unable to participate in that major life activity outside the workplace as well.

Since the spring of 1998, when the U.S. Supreme Court decided in Sutton v. United Airlines et al. that in determining whether an individual has a disability under the Americans with Disabilities Act, a court must consider the effects of any mitigating measures like medication, it has become increasingly difficult for people with epilepsy to persuade the courts that they are disabled under the ADA and entitled to the law's protections. Although the latest Supreme Court opinion narrows the scope of the ADA, it is possible that this decision will actually make it easier for people with epilepsy to persuade the courts that their condition is a disability under the ADA.

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. Ms. Williams claimed she was disabled because she had a physical impairment that substantially limited her ability to perform the major life activity of manual tasks in the workplace; she could perform a wide range of manual tasks, such as brushing her teeth, sweeping, and gardening, outside of the workplace. The federal Court of Appeals for the Sixth Circuit concluded Ms. Williams was disabled since her carpal tunnel syndrome substantially limited her ability to perform manual tasks in the workplace even though it did not limit her in her ability to brush her teeth or sweep. The Supreme Court's decision reverses the appeals court ruling, saying that the lower court 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 was sent back to the lower court to determine whether Ms. Williams' carpal tunnel syndrome affects her ability to perform manual tasks outside of work as well as at work.

The Supreme Court clarified what makes an activity a "major life activity", explaining that major life activity "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. This interpretation in effect may broaden the definition given to "major life activities" by many prior court decisions, which generally limit major life activities to bodily functions such as seeing, walking and sleeping. Now courts may have to recognize such common activities such as driving as a major life activity, and also consider the wide-ranging effects of epilepsy on an individual's life, rather than just looking at each individual limitation.

The Court's decision also makes clear that an individual can be substantially limited in a major life activity unrelated to work, such as reproduction, and still qualify as disabled under the ADA. This is important because, as recently as May of 2001, the Eleventh Circuit Court of Appeals recognized that an individual with epilepsy was substantially limited in her ability to reproduce but was not disabled under the ADA because the limitations on her ability to reproduce did not affect her ability to work. This reasoning appears to now be wrong under the Toyota decision. Rather the test will be whether epilepsy substantially limits the individual from engaging in activities of daily living, including such things as reproduction, sleeping, self-care, driving, etc. We will have to wait and see how the lower courts apply the Toyota ruling. In the meantime, we will continue to report on current cases involving people with epilepsy on our On the Docket feature of the website and also continue to provide attorneys and advocates with technical assistance.

©2002 While this material is designed to provide accurate and current information on the subject matter involved, the Epilepsy Foundation and the authors cannot guarantee the accuracy or completeness of the information contained in this publication. This fact sheet is not a legal document and does not provide legal advice or opinion. If legal advice or other expert assistance is required, the services of a competent professional should be sought.