Under the Americans with Disabilities Act of 1990 (ADA or Act), [citation], a physical impairment that ‘‘substantially limits one or more * * * major life activities’’ is a ‘‘disability.’’ [Citation.] Respondent, claiming to be disabled because of her carpal tunnel syndrome and other related impairments, sued petitioner, her former employer, for failing to provide her with a reasonable accommodation as required by the ADA. [Citation.] The District Court granted summary judgment to petitioner, finding that respondent’s impairments did not substantially limit any of her major life activities. The Court of Appeals for the Sixth Circuit reversed, finding that the impairments substantially limited respondent in the major life activity of performing manual tasks, and therefore granting partial summary judgment to respondent on the issue of whether she was disabled under the ADA. We conclude that the Court of Appeals did not apply the proper standard in making this determination because it analyzed only a limited class of manual tasks and failed to ask whether respondent’s impairments prevented or restricted her from performing tasks that are of central importance to most people’s daily lives. 

I

   Respondent began working at petitioner’s automobile manufacturing plant in Georgetown, Kentucky, in August 1990. She was soon placed on an engine fabrication assembly line, where her duties included work with pneumatic tools. Use of these tools eventually caused pain in respondent’s hands, wrists, and arms. She sought treatment at petitioner’s in-house medical service, where she was diagnosed with bilateral carpal tunnel syndrome and bilateral tendinitis. Respondent consulted a personal physician who placed her on permanent work restrictions that precluded her from lifting more than 20 pounds or from ‘‘frequently lifting or carrying of objects weighing up to 10 pounds,’’ engaging in ‘‘constant repetitive * * * flexion or extension of [her] wrists or elbows,’’ performing ‘‘overhead work,’’ or using ‘‘vibratory or pneumatic tools.’’ [Citation.]

   In light of these restrictions, for the next two years petitioner assigned respondent to various modified duty jobs. Nonetheless, respondent missed some work for medical leave, and eventually filed a claim under the Kentucky Workers’ Compensation Act. [Citation.] The parties settled this claim, and respondent returned to work. She was unsatisfied by petitioner’s efforts to accommodate her work restrictions, however, and responded by bringing an action in the United States District Court for the Eastern District of Kentucky alleging that petitioner had violated the ADA by refusing to accommodate her disability. That suit was also settled, and as part of the settlement, respondent returned to work in December 1993.

   Upon her return, petitioner placed respondent on a team in Quality Control Inspection Operations (QCIO). QCIO is responsible for four tasks: (1) ‘‘assembly paint’’; (2) ‘‘paint second inspection’’; (3) ‘‘shell body audit’’; and (4) ‘‘ED surface repair.’’ [Citation.] Respondent was initially placed on a team that performed only the first two of these tasks, and for a couple of years, she rotated on a weekly basis between them. In assembly paint, respondent visually inspected painted cars moving slowly down a conveyor. She scanned for scratches, dents, chips, or any other flaws that may have occurred during the assembly or painting process, at a rate of one car every 54 seconds. When respondent began working in assembly paint, inspection team members were required to open and shut the doors, trunk, and/or hood of each passing car. Sometime during respondent’s tenure, however, the position was modified to include only visual inspection with few or no manual tasks. Paint second inspection required team members to use their hands to wipe each painted car with a glove as it moved along a conveyor. The parties agree that respondent was physically capable of performing both of these jobs and that her performance was satisfactory.

   During the fall of 1996, petitioner announced that it wanted QCIO employees to be able to rotate through all four of the QCIO processes. Respondent therefore received training for the shell body audit job, in which team members apply a highlight oil to the hood, fender, doors, rear quarter panel, and trunk of passing cars at a rate of approximately one car per minute. The highlight oil has the viscosity of salad oil, and employees spread it on cars with a sponge attached to a block of wood. After they wipe each car with the oil, the employees visually inspect it for flaws. Wiping the cars required respondent to hold her hands and arms up around shoulder height for several hours at a time.

   A short while after the shell body audit job was added to respondent’s rotations, she began to experience pain in her neck and shoulders. Respondent again sought care at petitioner’s in-house medical service, where she was diagnosed with myotendinitis bilateral periscapular, an inflammation of the muscles and tendons around both of her shoulder blades; myotendinitis and myositis bilateral forearms with nerve compression causing median nerve irritation; and thoracic outlet compression, a condition that causes pain in the nerves that lead to the upper extremities. Respondent requested that petitioner accommodate her medical conditions by allowing her to return to doing only her original two jobs in QCIO, which respondent claimed she could still perform without difficulty. 

   The parties disagree about what happened next. According to respondent, petitioner refused her request and forced her to continue working in the shell body audit job, which caused her even greater physical injury. According to petitioner, respondent simply began missing work on a regular basis. Regardless, it is clear that on December 6, 1996, the last day respondent worked at petitioner’s plant, she was placed under a no-work-of-any-kind restriction by her treating physicians. On January 27, 1997, respondent received a letter from petitioner that terminated her employment, citing her poor attendance record.

   Respondent * * * filed suit against petitioner in the United States District Court for the Eastern District of Kentucky. * * *

   Respondent based her claim that she was ‘‘disabled’’ under the ADA on the ground that her physical impairments substantially limited her in (1) manual tasks; (2) housework; (3) gardening; (4) playing with her children; (5) lifting; and (6) working, all of which, she argued, constituted major life activities under the Act. Respondent also argued, in the alternative, that she was disabled under the ADA because she had a record of a substantially limiting impairment and because she was regarded as having such an impairment. [Citation.]

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   We granted certiorari, [citation], to consider the proper standard for assessing whether an individual is substantially limited in performing manual tasks. * * *

 II

   The ADA requires covered entities, including private employers, to provide ‘‘reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship.’’ [Citation.] The Act defines a ‘‘qualified individual with a disability’’ as ‘‘an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.’’ [Citation.] In turn, a ‘‘disability’’ is:

(A) a physical or mental impairment that substantially limits one or more of the major life activities of such individual;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment. §12102(2).

   There are two potential sources of guidance for interpreting the terms of this definition—the regulations interpreting the Rehabilitation Act of 1973, [citation], and the EEOC regulations interpreting the ADA. Congress drew the ADA’s definition of disability almost Chapter 43 Employment Law 917 verbatim from the definition of ‘‘handicapped individual’’ in the Rehabilitation Act and Congress’ repetition of a well-established term generally implies that Congress intended the term to be construed in accordance with pre-existing regulatory interpretations * * *.

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   To qualify as disabled, a claimant must further show that the limitation on the major life activity is ‘‘substantial.’’ [Citation.] Unlike ‘‘physical impairment’’ and ‘‘major life activities,’’ the HEW regulations do not define the term ‘‘substantially limits.’’ See Nondiscrimination on the Basis of Handicap in Programs and Activities Receiving or Benefiting from Federal Financial Assistance, citation (stating the Department of Health, Education, and Welfare’s position that a definition of ‘‘substantially limits’’ was not possible at that time). The EEOC, therefore, has created its own definition for purposes of the ADA. According to the EEOC regulations, ‘‘substantially limited’’ means ‘‘unable to perform a major life activity that the average person in the general population can perform’’; or ‘‘significantly restricted as to the condition, manner or duration under which an individual can perform a particular major life activity as compared to the condition, manner, or duration under which the average person in the general population can perform that same major life activity’’ [Citation.] In determining whether an individual is substantially limited in a major life activity, the regulations instruct that the following factors should be considered: ‘‘the nature and severity of the impairment; the duration or expected duration of the impairment; and the permanent or long-term impact, or the expected permanent or long-term impact of or resulting from the impairment.’’[Citation.]

    III

   The question presented by this case is whether the Sixth Circuit properly determined that respondent was disabled under * * * the ADA’s disability definition at the time that she sought an accommodation from petitioner. [Citation.] The parties do not dispute that respondent’s medical conditions, which include carpal tunnel syndrome, myotendinitis, and thoracic outlet compression, amount to physical impairments. The relevant question, therefore, is whether the Sixth Circuit correctly analyzed whether these impairments substantially limited respondent in the major life activity of performing manual tasks. Answering this requires us to address an issue about which the EEOC regulations are silent: what a plaintiff must demonstrate to establish a substantial limitation in the specific major life activity of performing manual tasks.

   Our consideration of this issue is guided first and foremost by the words of the disability definition itself. ‘‘Substantially’’ in the phrase ‘‘substantially limits’’ suggests ‘‘considerable’’ or ‘‘to a large degree.’’ [Citations.] The word ‘‘substantial’’ thus clearly precludes impairments that interfere in only a minor way with the performance of manual tasks from qualifying as disabilities. [Citation.]

   ‘‘Major’’ in the phrase ‘‘major life activities’’ means important. [Citation.] ‘‘Major life activities’’ thus refers to those activities that are of central importance to daily life. In order for performing manual tasks to fit into this category—a category that includes such basic abilities as walking, seeing, and hearing—the manual tasks in question must be central to daily life. If each of the tasks included in the major life activity of performing manual tasks does not independently qualify as a major life activity, then together they must do so.

   That these terms need to be interpreted strictly to create a demanding standard for qualifying as disabled is confirmed by the first section of the ADA, which lays out the legislative findings and purposes that motivate the Act. [Citation.] When it enacted the ADA in 1990, Congress found that ‘‘some 43,000,000 Americans have one or more physical or mental disabilities.’’ [Citation.] If Congress intended everyone with a physical impairment that precluded the performance of some isolated, unimportant, or particularly difficult manual task to qualify as disabled, the number of disabled Americans would surely have been much higher. [Citation.]

   We therefore hold that to be substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives. The impairment’s impact must also be permanent or long-term. [Citation.]

   It is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment. Instead, the ADA requires those ‘‘claiming the Act’s protection * * * to prove a disability by offering evidence that the extent of the limitation [caused by their impairment] in terms of their own experience * * * is substantial.’’ [Citation.] That the Act defines ‘‘disability’’ ‘‘with respect to an individual,’’ [citation], makes clear that Congress intended the existence of a disability to be determined in such a case-by-case manner. [Citations.]

   An individualized assessment of the effect of an impairment is particularly necessary when the impairment is one whose symptoms vary widely from person to person. Carpal tunnel syndrome, one of respondent’s impairments, is just such a condition. While cases of severe carpal tunnel syndrome are characterized by muscle atrophy and extreme sensory deficits, mild cases generally do not have either of these effects and create only intermittent symptoms of numbness and tingling. 918 Part 9 Regulation of Business [Citation.] Studies have further shown that, even without surgical treatment, one quarter of carpal tunnel cases resolve in one month, but that in 22 percent of cases, symptoms last for eight years or longer. [Citation.] * * * Given these large potential differences in the severity and duration of the effects of carpal tunnel syndrome, an individual’s carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA.

IV 

   The Court of Appeals’ analysis of respondent’s claimed disability suggested that in order to prove a substantial limitation in the major life activity of performing manual tasks, a ‘‘plaintiff must show that her manual disability involves a ‘class’ of manual activities,’’ and that those activities ‘‘affect the ability to perform tasks at work.’’ Both of these ideas lack support.

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   While the Court of Appeals in this case addressed the different major life activity of performing manual tasks, its analysis circumvented [citation] by focusing on respondent’s inability to perform manual tasks associated only with her job. This was error. When addressing the major life activity of performing manual tasks, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people’s daily lives, not whether the claimant is unable to perform the tasks associated with her specific job. Otherwise, * * * restriction[s] on claims of disability based on a substantial limitation in working will be rendered meaningless because an inability to perform a specific job always can be recast as an inability to perform a ‘‘class’’ of tasks associated with that specific job.

   There is also no support in the Act, our previous opinions, or the regulations for the Court of Appeals’ idea that the question of whether an impairment constitutes a disability is to be answered only by analyzing the effect of the impairment in the workplace. * * *

   Even more critically, the manual tasks unique to any particular job are not necessarily important parts of most people’s lives. As a result, occupation-specific tasks may have only limited relevance to the manual task inquiry. In this case, ‘‘repetitive work with hands and arms extended at or above shoulder levels for extended periods of time,’’ the manual task on which the Court of Appeals relied, is not an important part of most people’s daily lives. The court, therefore, should not have considered respondent’s inability to do such manual work in her specialized assembly line job as sufficient proof that she was substantially limited in performing manual tasks.

   At the same time, the Court of Appeals appears to have disregarded the very type of evidence that it should have focused upon. It treated as irrelevant ‘‘the fact that [respondent] can * * * tend to her personal hygiene [and] carry out personal or household chores.’’ Yet household chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives, and should have been part of the assessment of whether respondent was substantially limited in performing manual tasks.

   The District Court noted that at the time respondent sought an accommodation from petitioner, she admitted that she was able to do the manual tasks required by her original two jobs in QCIO. In addition, according to respondent’s deposition testimony, even after her condition worsened, she could still brush her teeth, wash her face, bathe, tend her flower garden, fix breakfast, do laundry, and pick up around the house. The record also indicates that her medical conditions caused her to avoid sweeping, to quit dancing, to occasionally seek help dressing, and to reduce how often she plays with her children, gardens, and drives long distances. But these changes in her life did not amount to such severe restrictions in the activities that are of central importance to most people’s daily lives that they establish a manual-task disability as a matter of law. On this record, it was therefore inappropriate for the Court of Appeals to grant partial summary judgment to respondent on the issue whether she was substantially limited in performing manual tasks, and its decision to do so must be reversed.

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   Accordingly, we reverse the Court of Appeals’ judgment granting partial summary judgment to respondent and remand the case for further proceedings consistent with this opinion.