Supreme Court Decisions Narrow Focus of the ADA

U.S. Supreme Court decisions regarding the Americans with Disabilities Act have narrowed the reach of the law, putting pressure on plaintiffs to prove they are entitled to protection against discrimination.

In June 1999, the court issued three opinions dealing with the issue of whether an individual has a disability when the impairment is controlled by medication or assistive devices. All three cases involved individuals who were denied employment solely because of physical impairment, despite the use of corrective measures that enabled them to function in the workplace. The cases included:

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--Sutton v. United Airlines: Twin sisters with severe nearsightedness applied for positions with U.S. Airways, which refused to hire them because they did not meet the company's minimum vision requirements of an uncorrected visual acuity of 20/100 or better. With corrective lenses, the twins had 20/20 vision or better and, thus, could function the same as individuals without vision impairments. The plaintiffs claimed they were denied employment because of their disabilities, in violation of the ADA. The court ruled that, with the use of corrective measures, the plaintiffs' visual impairments did not substantially limit a major life activity, and they were not considered "disabled" under the ADA.

--Murphy v. United Parcel Service Inc.: This case involved a mechanic who was fired from his position at UPS because of high blood pressure. Without medication, his blood pressure was approximately 250/160, which is above the U.S. Department of Transportation's recommendations for certification. With medication, the plaintiff functioned normally, except for limitations on his ability to lift heavy objects. The court evaluated the plaintiff's condition in his corrected state and ruled that he was not substantially limited in a major life activity, and therefore was not considered disabled under the ADA.

--Albertson's Inc. v. Kirkingburg: The plaintiff claimed that Albertson's fired him from his position as a truck driver because he suffered from amblyopia, an uncorrectable condition that results in monocular vision. Despite his clean driving record and certification by his state's Department of Transportation, Albertson's fired him. The court reversed a 9th U.S. Circuit Court of Appeals decision that monocular vision constitutes a disability per se and held that a plaintiff's ability to make subconscious physical adjustments must be considered in assessing whether the individual is disabled under the ADA.

--Williams v. Toyota: In 2002, the court ruled that an "impairment" must prevent a person from performing tasks important to daily life before it can be considered a "disability." The plaintiff sued the Toyota Motor Corporation's Georgetown, Ky., plant for failing to accommodate her carpal tunnel syndrome. Although Williams could not perform some of the manual tasks required by her job, the court ruled that she was not substantially limited in a major life activity and not disabled.

The American Trucking Associations Inc. called this "keeping the lid on ADA litigation. If the business community has its way, workers with conditions like Williams' and other 'nontraditional' disabilities who face discrimination on the job because of their injuries will never even get a chance to make their case in court."

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October 1, 2007

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