Facts
Supreme Court Decision
Comment
In the most recent of a string of decisions which have narrowed the scope of the federal Americans with Disabilities Act, the US Supreme Court narrowly construed the act's definition of 'disability' in Toyota Motor Manufacturing, Kentucky Inc v Williams.(1) The act defines 'disability', in part, as "a physical or mental impairment that substantially limits one or more of the major life activities of [an] individual".(2) Toyota Motor provided an opportunity for the High Court to explain precisely what is required to meet this standard.
Ella Williams, an assembly line worker for Toyota, developed carpal tunnel syndrome and tendinitis as a result of using pneumatic tools on the job. After her doctor recommended that she cease using such tools and refrain from repeated reaching and lifting, Toyota assigned her to the body paint inspection group, where her work did not entail these physical activities. Her condition was soon alleviated. Following three years in that group, Toyota added new duties to Williams's work regimen, including gripping a wooden-handled sponge. Soon after, her carpal tunnel syndrome and tendinitis returned in a more severe fashion. Williams claimed that she was refused permission to resume her prior, less physically demanding, paint inspection duties. Toyota later terminated her position.
Williams sued under the Americans with Disabilities Act, asserting that Toyota had violated the act by failing to provide her with a reasonable accommodation. A Kentucky district court rejected that argument, finding that her impairments did not meet the act's definition of 'disability'. The Sixth Circuit Court of Appeals reversed and ruled in Williams's favour. The appellate court reasoned that Williams had established that her impairments substantially limited her in the major life activity of performing manual tasks associated with an assembly line job. In reaching this conclusion, the court stressed that Williams was unable to do such manual work-related tasks as gripping tools and keeping her hands and arms extended at or above shoulder level. The Sixth Circuit disregarded evidence that Williams was able to tend to her own personal hygiene and to perform a range of personal and household chores, reasoning that this had no bearing on the determination that "her impairment substantially limit[ed] her ability to perform the range of manual tasks associated with an assembly line job".(3)
Toyota appealed to the Supreme Court.
In a unanimous opinion authored by Justice O'Connor, the High Court reversed and ruled in favour of Toyota. The court held that the Sixth Circuit erred by considering only a limited class of manual tasks and neglecting to consider whether Williams's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives.(4)
The court began its analysis by noting that the term 'substantially' in the phrase "substantially limits" under the Americans with Disabilities Act's definition of 'disability' suggests 'considerable' or 'to a large degree'.(5) Therefore, any impairments that "interfere in only a minor way with the performance of manual tasks" are not actionable under the act. The court went on to explain that the term 'major' in the definitional phrase "major life activities" means 'important'.(6) "'Major life activities' thus refers to those activities that are of central importance to daily life."(7) Following on from these observations, the 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."(8)
The court added that this determination must be made in on a case-by-case basis, particularly where "an impairment is one [like carpal tunnel syndrome] whose symptoms vary widely from person to person".(9)
The court next turned to the Sixth Circuit's analysis of Williams's impairment and rejected its narrow focus on her inability to perform tasks associated only with an assembly line job. Instead, the court held:
"When addressing the major life activity of performing manual tasks, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job."(10)
The Toyota Motor court went even further, minimizing the importance of work activities relative to the activities of day-to-day life by observing that "the manual tasks unique to any particular job are not necessarily important parts of most people's lives". Instead, the court opined that the relevant focus of the disability inquiry is on "[t]he types of manual tasks of central importance to people's daily lives", such as "household chores, bathing and brushing one's teeth".(11) The Supreme Court thus rejected the Sixth Circuit's finding that Williams was disabled, because that court failed to consider her ability to perform personal and household chores, and attend to her personal hygiene.
The Toyota Motor ruling is the latest Supreme Court decision to constrict the scope of the Americans with Disabilities Act In its wake, employees will no longer be able to sustain a cause of action by claiming that their impairment diminishes their ability physically to perform their job. Instead, they must put forth evidence that their everyday activities are significantly impeded.
For further information on this topic please contact Kevin B Leblang or Robert N Holtzman at Kramer Levin Naftalis & Frankel LLP by telephone (+1 212 715 9100) or by fax (+1 212 715 8000) or by email ([email protected] or [email protected]).
Endnotes