Toyota Motor Mfg., Ky., Inc. v. Williams

Toyota Motor Mfg., Ky., Inc. v. Williams,
No. 00-1089 (U.S. Jan. 8, 2002)

The United States Supreme Court held that an individual is disabled under the
Americans with Disabilities Act only if the individual has an impairment that
prevents or severely restricts him or her from performing activities that are
of central importance to most people’s lives.

This controversy arose when an employee at a car manufacturing plant developed
carpal tunnel syndrome and other musculoskeletal conditions that prohibited
her from performing one of the four tasks that she was regularly assigned to
on the assembly line: wiping down cars with polish as they passed on a conveyor
belt. She sued her employer under the ADA, alleging that it failed to accommodate
her disability by rejecting her requests to be removed from positions on the
assembly line that involved the performance of manual tasks at shoulder height.
The District Court granted summary judgment in favor of the employer, finding
that the employee’s conditions did not qualify as a "disability" under
the ADA. The Sixth Circuit reversed, finding that the woman’s inability to perform
a distinct subset of manual tasks – those involving repetitive shoulder-height
movements – constituted a disability.

The United States Supreme Court explained that there are four requirements
to finding that an individual is disabled under the ADA. The individual must
have a (1)permanent or long-lasting (2) physical or mental impairment (3) that
substantially limits (4) a major life activity. The issue in this case was whether
the employee was limited in a "major life activity" since she was
only substantially limited in her ability to perform routine manual tasks at
shoulder level or above for long periods of time.

The Supreme Court held that a major life activity is one that is of central
importance to daily life. It gave as examples the brushing of one’s teeth, bathing,
and carrying out household chores. The Court also found that performing manual
functions is a major life activity. But the Court decided that the Sixth Circuit
erred when it determined that the employee’s inability to perform a specific
subset of manual activities – those involving repetitive tasks at shoulder
height for long periods of time – constituted the inability to perform
a major life activity. The Supreme Court found that the Sixth Circuit should
have looked instead at whether the employee could perform the manual tasks that
are of central importance to daily life. Since the employee in this case could
perform the manual tasks that are of central importance to daily life –
maintaining hygiene, completing chores, gardening, doing laundry, and even completing
the manual tasks associated with two other positions on the assembly line –
she was not limited in a major life activity. The Court thus held that the employee
did not have a "disability" within the meaning of the ADA.