“…In Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999), the U.S. Supreme Court addressed the definitional problems under the ADA, citing a report prepared prior to the enactment of the federal law that noted, ''estimates of the number of disabled Americans ranged from an overinclusive 160 million under a 'health conditions approach,' which looked at all conditions that impair the health or normal functional abilities of an individual, to an underinclusive 22.7 million under a 'work disability approach,' which focuses on individuals' reported ability to work.' ' Kruse and Schur [2003] used 14 different definitions of disability in their study of the labor market, and found that, between 1990 and 1994, the employment rates declined for persons who reported work disabilities, but improved among persons who reported ADL limitations who did not report a work disability.…”