Supreme Court Narrows ADA: The Case of Toyota Motor Manufacturing, Inc. v. Williams
On January 8, 2002, the United States Supreme Court issued a landmark ruling in the case of Toyota Motor Manufacturing, Inc. v. Williams. The case is a victory for employers because the scope and application of the Americans with Disabilities Act ("ADA") in the employment context was substantially narrowed.
In order for an individual to qualify as "disabled" under the ADA, he or she must prove either that: (1) he or she suffers from a physical or mental impairment that substantially limits a "major life activity," (2) he or she has a record of such impairment, or (3) he or she is "regarded as" having such an impairment.
In Williams, the plaintiff alleged that she suffered from carpal tunnel syndrome, which substantially limited her ability to perform manual tasks. The trial court initially ruled that the plaintiff was not substantially limited in her ability to perform manual tasks. The Court of Appeals for the Sixth Circuit reversed, finding that the plaintiff was substantially limited in the performance of manual tasks because her impairment, "... limited her ability to perform the range of manual tasks associated with an assembly line job." The opinion focused on the plaintiff's ability to perform her job.
The United States Supreme Court reversed. In its ruling, the Court squarely addressed one central issue: What must a plaintiff demonstrate to establish a substantial limitation in the specific major life activity of performing manual tasks? The Court held that a physical or mental impairment must "prevent or severely limit" an individual in " ... activities that are of central importance to most people's daily life" and the impact of the impairment upon the individual must be permanent or long-term.
The Court stated that manual tasks unique to a particular job are not necessarily an important part of most people's lives, and thus occupation-specific tasks may have little relevance to the inquiry of whether a person is substantially limited in a major life activity. Instead of a job-specific inquiry, the Court referenced the performance of household chores and bathing and brushing one's teeth as the types of manual tasks that are of central importance in most people's lives. Therefore, an individualized assessment of the impairment's effect on the individual is necessary. In Williams, for instance, the plaintiff could brush her teeth, bathe, tend her flower garden, fix breakfast, do laundry and pick up around the house. Because of her physical impairment, however, she could not sweep or dance, needed occasional help dressing, had to limit playing with her children, gardening and driving. On that record, the Court could not conclude that she was substantially limited in the performance of major life activity.
Williams is important in the employment context because it makes it much more difficult for an employee with job-specific limitations to obtain protection under the ADA. An employee will now have to prove that his or her impairment substantially affects activities that are central to daily life and not merely to the job itself. For example, employees who are unable to lift extremely heavy amounts of weight, work overhead for extended periods of time, or who are unable to be around certain work-place chemicals might not be considered "disabled" under the ADA because those activities are not central to daily living. Williams limits the application of the ADA to individuals who have impairments that are serious enough to severely restrict or prevent activities that are central to daily life.
Employers should not, however, take Williams to mean that they do not have to reasonably accommodate employees under any circumstances. The question of whether an employee is disabled because he or she has an impairment that substantially limits a major life activity is a complex one, and legal advice will often be necessary to define your legal obligations under the ADA.