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Legal Digest
The Americans with Disabilities Act of 19901 (ADA) is a significant piece of social legislation. Yet, 12 years after its passage, its meaning still is debated. During its current term, the U.S. Supreme Court has decided three major cases involving unresolved issues arising under the ADA. The number of ADA cases heard by the Supreme Court this term alone is an indication of the act's impact on America's public and private workplaces.
The issues presented to the Supreme Court in these cases were: 1) the definition of an ADA disability relating to the performance of manual tasks; 2) the relationship between the ADA and binding arbitration agreements; and 3) the relationship between the ADA and seniority rules. This article reviews the facts of these important cases and discusses the Court's rulings.
ADA Basics
The ADA is an antidiscrimination statute. Its aim is to ensure that Americans with disabilities are treated fairly in the areas of employment, education, transportation, communications, recreation, institutionalization, health services, voting, and access to other public services.2 In the employment area, the ADA seeks to ensure that applicants for jobs and workers are judged on the basis of their abilities, not their disabilities.
Employers are prohibited by the ADA from discriminating against a "...qualified individual with a disability because of the disability...."3 A "qualified individual" is one who both meets the prerequisites for the position (e.g., education, job skills, and experience)4 and, despite a qualifying disability, is able to perform the essential functions of the job with or without a reasonable accommodation.5
A qualifying disability under the ADA can be either a physical or mental impairment.6 However, not just any impairment will do. To qualify as a disability, the impairment must substantially limit one or more of the major life activities of the claimant.7
Once individuals qualify for protection under the ADA, employers have an obligation to reasonably accommodate their disabilities.8 Only reasonable accommodations are required, however. An accommodation that would impose an undue hardship on the employer is not required.
Since the ADA was enacted, American courts have struggled with the meaning of the ADA. The struggle continues, as the following cases demonstrate.
Substantial Limits on Major Life Activities
Ella Williams began working for the Toyota Motor Manufacturing company...