6th Circuit Finds Carpal Tunnel Syndrome A Protected Disability

At least one federal court has suggested that carpal tunnel syndrome may be a protected disability which requires reasonable accommodation under the Americans With Disabilities Act (ADA).   In order to qualify as an individual with a disability under the ADA, the employee must establish that he or she has a "disability."  The ADA defines "disability" in three different ways:  (1) a physical or mental impairment that substantially limits one or more of the employee''s major life activities; (2) a record of such an impairment, or (3) being regarded as having such an impairment.  (42 U.S.C. § 12102(2)).

 

In Williams v. Toyota Motor Manufacturing, 2000 FED App. 0287A (6th Cir.), an August  29, 2000 6th Circuit Court of Appeals decision, the discussion focused on whether the employee was substantially limited in performing a broad class of jobs, thereby substantially limiting her in a major life activity.  The employee''s carpal tunnel arguably precluded her from performing manual task jobs.  In deciding that the employee was a protected individual under the ADA, the Court indicated that the employee''s carpal tunnel and corresponding restrictions were "analogous to having missing, damaged or deformed limbs that prevent her from doing the tasks associated with certain types of manual assembly line jobs, manual product handling jobs and manual building trade jobs . . .."  The Court determined that being limited in performing the major life activity of "performing manual tasks" was enough to require the protections of the ADA, and perform the reasonable accommodation analysis. 

 

The decision illustrates the fact-specific nature of each and every claim under the ADA.  This decision also is a good reminder to not view workers'' compensation, FMLA or ADA claimants in isolation - these three statutory schemes are inter-related, and while protecting yourself or minimizing your exposure under one statute, you may be setting up your employee''s claim under another.  Tread carefully when dealing with employees with injuries or disabilities.  The interrelationship between workers'' compensation, FMLA and ADA will be one of the topics at our 7th annual Employment Law Seminar on March 14, 2001 in Duluth, MN. 

 

The information provided in this article is general in nature and should not be used as a substitute for professional services and advice.  Readers should consult with their legal counsel before taking any action on matters covered in this article.