United States: In a Victory for Employers, Supreme Court Narrows Definition of "Disability" Under the ADA

Originally published in February 2002

On January 8, 2002, the United States Supreme Court issued one of the first in a series of important employment law-related decisions expected from the Court's October 2001 Term. In Toyota Motor Manufacturing, Kentucky, Inc. v. Williams¹ the Supreme Court held that the Court of Appeals incorrectly analyzed whether an employee—who claimed she was unable to perform manual tasks—was "disabled" as defined by the Americans with Disabilities Act ("ADA"). In so doing, the Court appears to have limited the ability of employees to establish claims under the ADA.

Plaintiff, Ella Williams, was an assembly line worker. In 1993, Williams developed carpal tunnel syndrome in her hands, wrists and arms from the repetitive use of certain tools on the job. Toyota transferred Williams to a quality control job where she visually scanned the exteriors of cars passing on the assembly line and wiped auto bodies with a glove. She was able to perform both of these functions without difficulty.

In 1996, however, Toyota added new tasks to the quality control position that required Williams to hold her hands at shoulder height for several hours at a time. She experienced pain in her neck and shoulders, and she was diagnosed with certain medical conditions. Williams asked Toyota to allow her to perform only the tasks she performed in the original quality control job. Williams claimed that Toyota refused her request and forced her to continue performing the additional quality control tasks, which caused her greater physical injury. Toyota claims that Williams simply stopped coming to work and terminated her for poor attendance.

Williams sued under the ADA, claiming that she was disabled and that Toyota had failed to accommodate her disability. In order to qualify as "disabled" under the ADA, an employee must have a physical or mental impairment that "substantially limits" one or more major life activities.² Williams argued that she was "substantially limited" in her ability to perform manual tasks, as well as to perform housework, work in the garden, play with her children, lift things and work, generally. Toyota argued that she was not "substantially limited," and, thus not disabled, because she could still perform a number of daily tasks, e.g., household chores, brushing her teeth, making meals and bathing. The district court dismissed the case, holding that Williams was not disabled within the meaning of the ADA. The United States Court of Appeals for the Sixth Circuit reversed, holding that Williams had demonstrated that she was substantially limited in her ability to perform manual tasks.

The Supreme Court reversed. It held that the Sixth Circuit had incorrectly analyzed whether Williams was disabled because it improperly focused on whether she could perform the manual tasks relating to her job. The Supreme Court stated that, instead, the analysis should be based on whether the impairment restricted Williams from performing tasks that are of central importance to most people's daily lives. The Court remanded the case with the following instructions:

• To determine whether an individual is "disabled," the individual's impairment must be assessed on a case-by-case basis (i.e., an individual may not be deemed automatically disabled simply because she has been diagnosed with an impairment). The impairment's impact must be permanent or long-term.
• The court's analysis should not be limited to whether the claimant can perform the duties of her job. For example, in order to be considered substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing manual tasks that are of central importance to most people's daily lives.

The Toyota decision is instructive on many levels. Indeed, the Court reaffirmed its prior precedent that the ADA was not designed to protect people with only minor or temporary impairments, but rather only those with very severe impairments. In addition, the Court also reaffirmed that in order for an individual to be deemed substantially limited in the major life activity of "working," the individual is required to show an inability to work in a "broad range of jobs" rather than just a specific job. The Court also suggested that the EEOC's broad regulations interpreting the ADA may not be entitled to deference.

Taken together, Toyota and some of the Court's other recent ADA decisions signal a rejection of the attempts of the EEOC and the plaintiffs' bar to broaden the scope of the ADA.

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