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Law & Psychiatry: The U.S. Supreme Court Narrows the Definition of Disability Under the Americans with Disabilities Act

by John Petrila, J.D., LL.M.


Petrila (2002) reports on the case of Toyota Motor Manufacturing, Kentucky Inc. v. Williams. Petrila writes, "The U.S. Supreme Court recently issues a unanimous opinion that makes it more difficult for employees to prevail in work-related claims under the Americans with Disabilities Act (ADA)." In the above mentioned case, the Court clarified the legal principles that govern the determination of disability under the ADA. This decision by the Supreme Court will make it more difficult for people with mental illnesses to successfully pursue claims under the ADA. Petrila reports,

"The Supreme Court appears to be moving toward a conclusion that work is not considered a major life activity under the ADA, a conclusion that would create further difficulties for employees who attempt to bring disability claims under the statute. Such a ruling would mean that the effect of an impairment, mental or physical, on a person's ability to undertake work would no longer be the primary issue in any employment claim brought under the ADA. Rather the inquiry would be whether the person was able to perform the types of tasks discussed by the Court in Toyota Motor, such as bathing, personal hygiene, and household chores."

This would suggest that a person must show a very high level of general impairment before qualifying as having a disability under the ADA. Petrila concludes,

"The Toyota Motor case will push the inquiry in employment cases away from the workplace and toward ordinary living situations and may result over time in a narrowing of the applicability of the ADA to persons with the most severe disabilities."

Petrila suggests this result appears to run counter to the true spirit of the ADA, which originally invited a broad reading of what "disability" is so that people with disabilities could engage in employment and other activities that were often denied them. Finally, Petrila suggests that accumulating impact of the Supreme Court's decisions might create new barriers for some individuals with mental and physical disabilities.


Petrila, J. P. (2002). Law & Psychiatry: The U.S. Supreme Court narrows the definition of disability under the Americans with Disabilities Act. Psychiatric Services, 53(7), 797-801.

Full Text Article is available at Psychiatric Services