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Employees must meet a demanding standard to qualify for protection as “disabled” under the Americans with Disabilities Act. Employers may have more difficulty determining when the standard is met, however, because they must assess whether an employee’s impairment prevents or restricts her from doing activities that are of central importance to most people’s daily lives away from work, permanently or for the long-term, and not only from doing tasks associated with a particular job.

In Toyota Motor Manufacturing v. Williams, Williams was an assembly line worker with carpal tunnel syndrome and related impairments. She could not perform repetitive work with her hands and arms extended up around shoulder height for hours at a time. She sued Toyota for including these tasks in her job and firing her for excessive absenteeism. The U.S. Supreme Court reversed the appeals court’s decision that she was “disabled” under the ADA.

As the Court explained, an impaired employee is “disabled” under the ADA if she is “substantially limited” in one or more “major life activities”. That is “a demanding standard”. An employee is not disabled unless her impairment prevents or restricts her from doing activities that are of central importance to most people’s daily lives. The impairment’s impact must also be permanent or long term.Williams could not satisfy these requirements by showing that she was unable to perform the tasks associated with her specific job.

Although the Williams opinion only covers the major life activity of performing manual tasks, the Court’s analysis should guide an employer’s determination whether an employee has a legally protected disability based on limitation of most other major life activities. In analyzing whether an impairment prevents or severely restricts an employee’s ability to perform one or more major life activities, employers should not rely solely on evidence of a medical diagnosis. They should individually assess the effect of the employee’s impairment both inside and outside of the workplace, and determine to what extent the impairment permanently or for the long term prevents or severely restricts the employee from doing activities that are of central importance to most people’s daily lives.

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