Summary of Williams v. Toyota Manufacturing
The Supreme Court's Review of the Definition of Disability Under the ADA
Barry C. Taylor Legal Advocacy Director, Equip for Equality, Inc.
The Facts of the Williams Case
Ella Williams worked for Toyota Manufacturing, and she was transferred to a different position when the tasks she had been performing caused her to develop carpal tunnel syndrome and tendonitis. Initially, Williams was able to perform in her new position without experiencing any pain. However, Toyota later required her to perform additional tasks in which she had to hold her hands and arms up at shoulder height for several hours at a time. As a result, Williams experienced pain in her neck and shoulders, and her ligament and muscle problems reappeared in a more severe form. Williams requested that the employer provide her with a reasonable accommodation under the ADA that would permit her to only perform the original tasks of her job that did not exacerbate her disabilities. The employer refused and she sued under the ADA alleging that she was covered by the ADA because her physical impairments substantially limited her in the major life activities of performing manual tasks, working and lifting.
Lower Court Decisions in the Case
The trial court granted summary judgment in favor of Toyota finding that Williams did not have an ADA disability, and therefore, she was not entitled to protection under the Act. On appeal, the Sixth Circuit Court of Appeals held that Williams had presented sufficient evidence for a jury to decide whether her impairments substantially limited her in the major life activity of performing manual tasks entitling her to coverage under the ADA. The court stated that her ability to do certain household manual tasks was not determinative with respect to whether her impairment substantially limited her ability to perform the range of manual tasks associated with her assembly line job. The court declined to decide whether Williams was substantially limited in the major life activities of working or lifting.
Supreme Court's Ruling
The U.S. Supreme Court agreed to hear the case and held that the Sixth Circuit did not apply the proper standard in determining that Williams has a disability under the ADA because it analyzed only the manual tasks of her specific job, and failed to ask whether Williams' impairments prevented or restricted her from performing tasks that are of a "central importance to most people's daily lives." The Court also stated that when determining whether a person has a disability, courts must do an individualized assessment to determine if there is a substantial limitation, especially for those impairments (like carpal tunnel syndrome) in which the symptoms greatly vary from person to person. Accordingly, the case was returned to the lower court to re-examine whether Williams has an ADA disability.
Potential Implications of the Case
- Plaintiffs who claim to be covered by the ADA because they are substantially limited in the major life activity of performing manual tasks must be able to show that these limitations are for activities that are central to most people's lives such as performing household chores, bathing, brushing one's teeth and dressing.
- The Supreme Court held that the ADA disability definition applies beyond major life activities associated with employment. This may prove useful to people with disabilities because relying on major life activities associated with working often will result in a court finding that the person is not qualified to perform the essential functions of the job.
- Plaintiffs whose primary limitations are related to a specific job will have a much more difficult time convincing a court that they are covered by the ADA.
- Although the Supreme Court did not rule in Williams' favor, it also did not hold that she failed to show that she had an ADA disability. The Court only ruled that the Sixth Circuit had not applied the correct legal standard. Accordingly, the lower court could still find that Williams does have an ADA disability. (i.e. because she is substantially limited in the major life activity of lifting.)
- The Supreme Court affirmed its previous rulings that courts must do an individualized assessment to determine if plaintiff is substantially limited in a major life activity, especially for impairments in which the symptoms greatly vary from person to person.
- Because the Supreme Court refused to find that Williams was not covered under the ADA as a matter of law, employers may have a more difficult time in the future persuading courts to rule as a matter of law that an employee does not have an ADA disability. This could result in more cases going to trial or favorably settling.
- The Supreme Court stated that examining whether a plaintiff is substantially limited in a class of jobs is only appropriate for the major life activity of working. However, the Court expressed doubts as to whether "working" is a major life activity under the ADA.
- The Supreme Court did not address whether reassignment can be an ADA reasonable accommodation.
- The Supreme Court did not decide whether Williams was covered by the ADA because she either had a record of a disability or was regarded as having a disability.
- Plaintiffs who may have d ifficulty proving a substantial limitation in a major life activity should consider filing a claim under state or local disability law, many of which do not require a plaintiff to have a substantial limitation.
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