Toyota Motor Mfg. v. Williams

Supreme Court narrows interpretation of what constitutes a disability under the ADA:

Toyota Motor Mfg. v. Williams

Issued on January 8, 2002, the Supreme Court’s latest decision on the American with Disabilities Act (ADA) overturns a 6th Circuit victory for an automobile assembly line employee with carpal tunnel syndrome, and has been described as a "victory" for businesses and employers. In Toyota Motor Mfg. v. Williams, the Supreme Court unanimously agreed that Ms. Williams continuing ability to perform such tasks as brushing her teeth, bathing and some household chores disqualified her from fitting within the ADA’s definition of disability, and therefore precluded her from claiming a right to reasonable accommodation from her employer.

Arlene Mayerson, Directing Attorney for Disability Rights Education and Defense Fund Inc., said the ruling was another step by the nation’s highest court to restrict the reach of the ADA, but also notes that "it is raising the bar, but is not closing the door. It is important that people with these types of injuries know that the ADA is still available if they can show that the impairment Ôsubstantially limits’ daily life activities."

Background

Ella Williams first developed carpal tunnel syndrome in her upper extremities, a condition that involves painful muscle and tendon injuries resulting from highly repetitive motions, when employed by Toyota as an assembly line worker using pneumatic tools. Toyota re-assigned Williams to other positions, and for three years she performed satisfactorily as a vehicle paint inspector. Eventually, Toyota required Williams to perform additional manual tasks, whereupon her pain reappeared. Williams requested an accommodation of her company-diagnosed medical condition and a return to her previous job as paint inspector. The two parties disagree on precisely what occurred next, but ultimately Williams stopped going to work and Toyota fired her.

The ADA’s definition of a "disability" refers in part to "a physical or mental impairment that substantially limits one or more of the major life activities" (¤12102(2)). Toyota initially won a motion for summary judgement when the District Court found that Williams’ impairment did not "substantially limit" a "major life activity" at the time she requested accommodation from her employer. Williams successfully appealed to the 6th Circuit Court of Appeals, who found that Williams satisfied the ADA’ requirements because she was disabled due to a substantial limitation in the ability to perform manual tasks at the time she requested accommodation from Toyota. The Court of Appeals stated that Williams’ ailments "prevent her from doing the tasks associated with certain types of manual assembly line jobs, manual product handling jobs and manual building trade jobs (painting, plumbing, roofing, etc.) that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time."

The Supreme Court Ruling

The Supreme Court unanimously reversed the Court of Appeals’ decision, fundamentally disagreeing with both the 6th Circuit’s use of a "class-based framework" to interpret the term "manual tasks" and the court’s willingness to limit their analysis to the effect of Williams’ impairment in the workplace. Instead, the Supreme Court held 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." In answer to Williams’ evidence that "her medical condition 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", the Supreme Court found that "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." The case was therefore remanded to the 6th Circuit Court of Appeals for reconsideration in light of the Supreme Court’s decision. This is very significant. The Supreme Court refused to hold that Williams was not disabled as a matter of law, leaving open the possibility that these types of cases can be decided by jurors who are more likely to be sympathetic after hearing live testimony.

Implications

At the heart of the high court’s analysis is the belief that the ADA’s use of terms, such as " "substantially limits" and "major life activities", "need to be interpreted strictly to create a demanding standard for qualifying as disabled." The decision follows a number of earlier Supreme Court cases that also narrowed the compass of the ADA (eg., Sutton v. United Airlines, Inc. (1999), held that individuals with conditions which could be corrected or controlled are not disabled under the ADA, and Univ. of Alabama v. Garrett (2001), held that states were protected by sovereign immunity from individual employee actions for monetary damages). The Supreme Court’s strict interpretation of the ADA could be regarded as an attempt to ensure that businesses and employers are not subject to lawsuits brought by employees who cannot perform "some isolated, unimportant, or particularly difficult manual task", but the decision presents many employees with disabilities with a quandary.

Mayerson, who wrote the amicus curiae brief of the National Council on Disability in support of Williams, states:

This court seems determined to set a very strict test for deciding who is disabled. You are either not disabled enough to be covered by the ADA or you are too disabled to do the job. That is not what Congress intended. A worker in Williams’ position is now faced with a Catch-22. At the same time they are trying to show how much the impairment affects their daily life, they are also trying to prove they are qualified for the job. By proving you’re disabled, you can prove yourself right out of a job.

The Supreme Court’s overemphasis on the definition of disability means that the question of whether a person has been discriminated against or could have been accommodated never sees the light of day. For Williams in particular, the January 10, 2002 New York Times editorial points out that "[a] Toyota plant has many tasks that would not aggravate her injury. Her situation was just what the law’s framers had in mind – a company should be expected to modify the conditions of someone’s work within reasonable limits. Accommodating Ms. Williams would have been neither difficult nor expensive for Toyota."