Supreme Court Update

Co-authored by Katie Colvin & Jim Petrie

Originally published in Labor Law Bulletin, June 2002

In our last issue (Vol. 22, No. 1, January 2002) we summarized five of the many employment cases on the U.S. Supreme Court's docket. The Court has since decided four of those cases. Two of them (Ragsdale v. Wolverine Worldwide, Inc., 122 S. Ct. 1155 (2002), and Hoffman Plastic Compound, Inc. v. NLRB, 122 S. Ct. 1275 (2002)) are discussed in detail elsewhere in this issue. Two others are summarized below (Williams v. Toyota Motor Mfg., Kentucky, Inc., 122 S. Ct. 681 (2002), and EEOC v. Waffle House, 122 S. Ct. 754 (2002)). The fifth case (Moran v. Rush Prudential HMO, Inc.) is still pending. We've also included in this article a couple of added starters, Edelman v. Lynchburg College, 122 S. Ct. 1145 (2002), which was decided in March, and Echazabal v. Chevron USA, in which oral argument was heard in February involving the "direct threat" defense under the ADA.

Toyota. An assembly line worker claimed that she was entitled to reasonable accommodation under the ADA because carpal tunnel syndrome and related impairments limited her ability to perform the range of repetitive manual tasks associated with her job. The Court concluded that the evidence was insufficient to show that she was disabled within the meaning of the Act. To prove a substantial limitation in the major life activity of performing manual tasks, one must demonstrate an impairment that prevents or restricts "activities that are of central importance to most people's daily lives." In the Court's opinion, manual tasks unique to a particular job are not as central to most people's daily lives as performing household chores, bathing and brushing one's teeth.

Although a victory for Toyota, this decision may mean that in determining its obligation to provide reasonable accommodation, in some instances an employer will have to consider what an employee can do away from work as well as on the job.

Waffle House. The Court held that an employee's agreement to arbitrate employment disputes has no effect on the EEOC's right to sue the employer in federal court for injunctive or victim-specific relief (e.g., back pay and damages). The Court noted that Title VII unambiguously gives the agency the right to obtain such remedies with no suggestion that this right is foreclosed by the existence of an arbitration agreement between private parties. The Court also looked at the Federal Arbitration Act...