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Originally appeared in Labor and Employment Newsletter - February 2002
On January 8, 2002, a unanimous Supreme Court held that a plaintiff must demonstrate that her impairments restrict activities central to most people’s daily lives in order to establish a substantial limitation in the major life activity of performing manual tasks. Toyota Motor Mfg. Ky. Inc. v. Williams, U.S., No. 00-1089. The case was closely watched by employers, particularly in the manufacturing sector, because of the broad implications of the holding by the Court of Appeals for the Sixth Circuit that an employee with carpal tunnel syndrome was substantially limited in the major life activity of performing manual tasks because her medical restrictions prevented her from performing many of the manual tasks of her assembly line job.
Lower Courts Disagree
Ella Williams claimed that she was disabled from performing her job on the assembly line by her carpal tunnel syndrome and related impairments and sued her former employer, Toyota, for failing to provide her with a reasonable accommodation as required under the ADA. Williams had a lifting restriction of 20 pounds and was precluded from frequently lifting objects over 10 pounds, from constant, repetitive extension of her wrists or elbows, and from performing overhead work or using vibratory or pneumatic tools. The district court held that Williams had failed to establish that she was substantially limited in any major life activity and granted summary judgment to Toyota. Reversing the summary judgment decision and granting Williams partial summary judgment, the Court of Appeals for the Sixth Circuit held that Williams was substantially limited in the performance of manual tasks because her impairments prevented her from performing the tasks associated with a class of manual activities. The Court of Appeals deemed irrelevant evidence that Williams was not restricted in performing personal or household chores.
Demanding Standard
The Supreme Court rejected the standard applied by the Sixth Circuit and held that the central inquiry to any determination of whether an individual is substantially limited in the major life activity of performing manual tasks must be whether the individual is "unable to perform the variety of tasks central to most people’s daily lives, not whether the [individual] is unable to perform the tasks associated with her specific job." In reaching this conclusion, the Court noted initially that the terms "major life activity" and "substantially limited" must be interpreted narrowly in order to "create a demanding standard for qualifying as disabled" as intended by Congress when it enacted the ADA. The Court further reasoned that the standard imposed by the Court of Appeals would render Sutton’s restriction on claims of disability based on a substantial limitation in the major life activity of working meaningless, because the inability to perform a specific job "can always be recast as the inability to perform a "class" of tasks associated with that job." Moreover, the Court noted, the manual tasks associated with a particular job are not necessarily important parts of most people’s lives and therefore may have limited relevance to the manual task inquiry. The Court specifically explained that Williams’ inability to perform, "repetitive work with hands and arms extended at or above shoulder levels for extended periods of time, . . . the manual task on which the Court of Appeals relied, is not an important part of most people’s daily lives."
Mayer, Brown & Platt filed an amicus brief in this case on behalf of the American Trucking Associations, Inc., the Association of International Automobile Manufacturers, and the Chamber of Commerce of the United States.
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