On January 8, 2002, the United States Supreme Court handed down a pivotal American with Disabilities Act decision which apparently represents a major victory for employers. Williams v. Toyota Motor Manufacturing concerned Ella Williams, an employee who began working for Toyota's Georgetown, Kentucky plant in 1990. First she developed carpal tunnel syndrome and her physician placed her on permanent work restrictions. Toyota then		assigned her to various modified duties over the next two years. Even so, she missed a lot of work and filed a claim under the state Worker's Compensation Act. Williams and Toyota settled this claim and she returned to work. Unsatisfied with her employer's efforts to accommodate her impairments, she then sued Toyota under the ADA for failing to accommodate her disability. That suit was also settled and she returned to work.

Upon her return to work in 1993, Toyota assigned her to a position as a quality-control inspector. In 1996, Toyota added to the duties of all quality-control inspectors. These new duties included wiping cars, which required her to hold her hands and arms up around shoulder height for several hours at a time. These new duties caused her to develop a form of tendonitis. She requested that Toyota not require her to wipe cars. Toyota either refused or Williams simply stopped coming to work. Regardless, Toyota then terminated her based on a poor attendance record. Williams filed, among other things, another ADA suit claiming Toyota failed to reasonably accommodate her disabilities.

Since the ADA's inception in 1990, the determination of what impairments are "disabilities" under the statute, and what "reasonable accommodations" must be made, has troubled both employers and the judicial system. The ADA protects only those individuals who have a "disability." Disability is statutorily defined as "as a physical or mental impairment that substantially limits one or more of the major life activities of an individual." In this case, the Supreme Court ruled that "major life activities" are not measured solely on the ability to do tasks related to job performance, but also an individual must be unable to perform "activities that are of central importance to most people's daily lives, such as walking, seeing and hearing."

Williams claimed that she was substantially limited in the major life activity of, among other things, "performing manual tasks." The district court dismissed her claim because she was not substantially limited in performing this activity. The 6th Circuit Court of Appeals reversed, holding that Williams was substantially limited because she was unable to perform a "class" of manual activities at work even though she was performed everyday tasks such as tending to personal hygiene and doing household chores.

A unanimous Supreme Court ruled that the 6th Circuit had used an improper standard to determine whether Williams was "substantially impaired." Based on the dictionary definition, the Court held that the term "substantial" suggests "considerable" or "to a large degree." Likewise, the term "major" in "major life activity" refers to "those activities that are of central importance to daily life." Thus, to be substantially limited in the major life activity of 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." The 6th Circuit erred by failing to address whether Williams' impairment substantially limited her in performing tasks that are central to her daily life. The Court remanded the case for consideration in light of this holding.

The importance of Toyota to employers is far reaching: employees that claim they are "disabled" under the ADA will have to show more than a substantial limitation in their ability to perform activities at work. They must demonstrate that they are substantially limited in activities that are of central importance to daily life. This does not mean that anyone with carpal tunnel syndrome, tendonitis, or other partial disabilities will be unable to claim the protection of the ADA, but the higher burden placed on such individuals will certainly reduce the number of successful claims.

Toyota is also notable for what the Court did not address. In the past, the Supreme Court has refused to decide whether "working" could be a major life activity. Although the EEOC claims that it can, this issue is unsettled in the courts. In Toyota, the Court expressly declined to "decide this difficult question." Although Williams raised this issue at both of the lower levels, the 6th Circuit found that it did not need to address the matter because it could decide the case using the major life activity of "performing manual tasks." Thus, the Supreme Court was able to once again escape a question that it appears to dread. As a result, parties to ADA claims and the lower courts will continue to struggle with the uncertainty of the statute on this question.

© 2002 Du Val Business Law, P.C. Suite 103 The Durham House 1012 SW King Ave.  Portland, Oregon

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