ADAAA Case Highlights Broadened Definition Of "Disability"

Since the U.S. Supreme Court's 2002 decision in Toyota v. Williams, employers have enjoyed a period of relative low risk in determining whether an employee is disabled under the Americans with Disabilities Act (ADA). Using Toyota, federal courts created a body of case law that made it difficult for an employee to qualify as disabled under the ADA. Further, when an employee did satisfy the "disabled" prong of the ADA analysis, the disability was often so severe that even with a reasonable accommodation, the employee was not considered "qualified" for the position in question.

This ended in 2008, when the ADA was amended to broaden the definition of "disability" to address what some viewed as an overly restrictive view of the statute. The result is a new and growing body of federal case law that grants disability status to conditions that would not have qualified as disabilities a few years ago, thereby triggering the duty for employers to engage in the collaborative