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In McKay v. Toyota Motor Manufacturing, the district court held that the plaintiff failed to show a substantial limitation to a major life activity, and that people who suffer from Carpal Tunnel Syndrome are not protected under the ADA.
In March 1992, McKay began to work in the body weld division at Toyota Motor Manufacturing (TMM). Within a few weeks, she started to complain about pain in her hands, forearms and wrists, as well as numbness and tingling. She was referred to a TMM physician who sent her home to rest. After she returned to work, the pain and swelling returned and she was referred to an orthopedic surgeon who diagnosed her with work-induced Carpal Tunnel Syndrome. McKay was given medication, splints for her arm and wrist, and physical therapy. The surgeon restricted her work by limiting the amount she could lift and prohibiting use of vibrating tools. Over the next year, McKay worked as often as she could in a variety of positions. In June 1993, due to excessive absences from work, TMM terminated McKay.
McKay sued TMM under the ADA, alleging that they denied her requests for light and medium duty jobs and that they refused to provide her with work conforming to the restrictions placed upon the use of her hands and arms. TMM moved for summary judgment.
The district court observed that the ADA prohibits discrimination against "a qualified individual with a disability." A "disability" is defined as "(i) a physical or mental impairment that substantially limits one or more of the major life activities; (ii) a record of such an impairment; or (iii) being regarded as having such an impairment. "Major life activities" include caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. The court noted that for an impairment to "substantially limit" one or more of these major life activities, "the individual must be unable to perform, or be significantly limited in the ability to perform, an activity compared to an average person in the general population."
The district court noted that courts reviewing substantial impairment "should" consider: "(i) the nature and severity of the impairment; (ii) the duration or expected duration of the impairment; and (iii) the permanent or long term impact, the expected permanent or long term impact, or the expected permanent or long term impact of or resulting from the impairment." The court also noted that courts "may" consider: (i) the geographical area to which the individual has reasonable access; (ii) the class of jobs; and (iii) a broad range of jobs in various classes. The court found that McKay must show a significant restriction in ability to perform either a class of jobs or a broad range of jobs in various classes as compared to the average person with comparable training, skills, and abilities. Further, the court stated that "inability to perform a single, particular job does not constitute a substantial limitation to the activity of working." The court noted that McKay, a college graduate working on a teaching certificate, was qualified for numerous positions not requiring skills learned and developed at TMM. Thus, she was not significantly limited under the ADA.
The district court also held that Carpal Tunnel Syndrome was not a protected disability under the ADA. The court then granted TMM's Motion for Summary Judgment.
McKay v. Toyota Motor Manufacturing, 878 F. Supp. 1012 (E.D. Ky. 1995), aff'd 110 F.3d 369 (6th Cir. 1997).