Supreme Court Decides ADA Case on Definition of Disability
On November 7, 2001, the Supreme Court heard oral argument in Toyota Motor Manufacturing,
Kentucky, Inc. v. Williams, involving the question of who is protected by the Americans with Disabilities Act.
On Tuesday, January 8, 2002, the court issued a unanimous decision.
The case was brought by a woman who was an assembly line worker for a car manufacturing plant in
Kentucky. The woman developed bilateral carpal tunnel syndrome in her wrists and bilateral tendonitis in her
neck, shoulders and arms as a result of gripping pneumatic tools to perform her job at the plant. She could no
longer perform certain functions of her job. As an accommodation, she was assigned to perform two of the
simpler jobs at the plant. After several years, Toyota began requiring her to perform other tasks as well,
which she was unable to do because of her carpal tunnel syndrome and tendonitis. She requested that,
as an accommodation, her job be modified to include only the tasks she was previously performing. Toyota
denied this request. As a result, Ms. Williams was ultimately forced to resign.
The court held that the Sixth Circuit had applied the wrong standard for determining whether the plaintiff
was substantially limited in performing manual tasks and remanded the case for consideration under the correct standards. The Sixth Circuit erroneously focused on tasks related only to work, the court ruled, saying that the
correct test is that an individual must have an impairment that prevents or restricts the individual from
doing activities that are of central importance to most people's daily lives. Work-related activities may be
considered but may be of limited relevance because they generally will not be the sort of activities that affect
most people's daily lives. The court held that it is not necessary to demonstrate limitations in a "class" of
activities. While Toyota had suggested that limitations in "working" may not be sufficient to constitute a
disability, the Supreme Court left this question for another day.
The district court had found that the woman was not a person with a disability
under the ADA and granted summary judgment for Toyota. The court said that Ms.
Williams was neither substantially limited in performing
manual tasks nor substantially limited in working. The Sixth Circuit reversed,
holding that Ms. Williams presented enough evidence about her substantial limitations
in manual tasks to avoid dismissal. The evidence supported her
claim, the appellate court found that, due to her inability to perform repetitive
motions and restrictions on her lifting, she was substantially limited in performing
a class of assembly line jobs and other jobs. She was also substantially limited
in performing other manual tasks outside of the workplace.
Toyota asked the Supreme Court to reverse the Sixth Circuit decision, arguing that the Sixth Circuit
created an "end run" around the difficult burden of showing that Ms. Williams is substantially limited in working.
Ms. William's brief and an amicus brief filed by the Bazelon Center for Mental
Health Law and other disability rights groups attempted to correct that mischaracterization and also to clarify the
proper standard for determining when a person is substantially limited in performing manual tasks. Portions of the
Sixth Circuit decision suggest that in order to establish a disability in performing manual tasks, an employee must
show that her limitations in performing manual tasks relate to the job at hand. The Bazelon Center amicus brief clarifies that a person with a disability based on substantial limitations in performing manual tasks need not show
that those limitations are related to work. The amicus brief also responds to the arguments of amici (e.g., the United
States solicitor general) supporting Toyota that the Court should rule that "working" is not itself a major life activity, and points out the flaws in these arguments. The National Council on Disability also filed an amicus brief in the Williams case.
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