LOCATION:United States District Court Eastern District of Louisiana
DOCKET NO.: 00-1089
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit
CITATION: 534 US 184 (2002)
ARGUED: Nov 07, 2001
DECIDED: Jan 08, 2002
Barbara B. McDowell – on behalf of the United States, as amicus curiae
Robert L. Rosenbaum – Argued the cause for the respondent
Facts of the case
In 1997, Toyota Motor Manufacturing, Kentucky, Inc. terminated Ella Williams, citing her poor attendance record. Subsequently, claiming to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, Williams sued Toyota for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA). Granting Toyota summary judgment, the District Court held that Williams’s impairment did not qualify as a disability under the ADA because it had not substantially limited any major life activity and that there was no evidence that Williams had had a record of a substantially limiting impairment. In reversing, the Court of Appeals found that the impairments substantially limited Williams in the major life activity of performing manual tasks. Because her ailments prevented her from doing the tasks associated with certain types of manual jobs that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time, the appellate court concluded that Williams demonstrated that her manual disability involved a class of manual activities affecting the ability to perform tasks at work.
Did the Court of Appeals use the proper standard in determining whether an employee was disabled under the ADA due to carpel tunnel syndrome by showing that her manual disability involved a class of manual activities affecting the ability to perform tasks at work?
Media for Toyota Manufacturing, Kentucky, Inc. v. Williams
Audio Transcription for Opinion Announcement – January 08, 2002 in Toyota Manufacturing, Kentucky, Inc. v. Williams
William H. Rehnquist:
The opinion of the Court No. 00-1089 Toyota Motor Manufacturing, Kentucky Inc. versus Williams will be announced by Justice O’Connor.
Sandra Day O’Connor:
This case is here on writ of certiorari to the Court of Appeals for the Sixth Circuit.
Respondent, who had worked on an Assembly line at the petitioner’s automobile manufacturing plant in Kentucky, sued the petitioner under the Americans with Disabilities Act referred to as the ADA.
She claimed to be disabled because of her carpal tunnel syndrome and related impairments and alleged that the petitioner had failed to provide her with reasonable accommodation as required under the Act.
The District Court granted summary judgment to Toyota finding that the respondent was not disabled under the ADA because her impairments did not substantially limit any of her major life activities.
She did not have a record of substantially limiting impairment and the employer had not regarded her as having such impairment.
The Court of Appeals reversed finding that her impairments substantially limited her in the major life activity of performing manual tasks and that she was therefore entitled to partial summary judgment on the issue of whether she was disabled.
The Court of Appeals held that an order to demonstrate that she was disabled due to her substantial limitation in performing manual tasks that the respondent had to show only that her manual disability involved a class of manual activities affecting the ability to perform those tasks at work.
The respondent had satisfied this test according to the Court of Appeals because her impairments prevented her from doing the tasks associated with certain types of manual assembly line jobs, manual product handling jobs, and manual building trade jobs that require the gripping of tools and repetitive work with hands and arms extended or at above shoulder levels for extended periods of time.
In reaching this conclusion, the Court of Appeals disregarded evidence that respondent could tend to her personal hygiene and carry out personal and household chores explaining that such evidence did not affect its determination.
We reversed the judgment of the Court of Appeals and hold that it did not apply to proper standard in determining whether respondent was disabled under the ADA, because it analyzed only a limited class of manual tasks and failed to asks whether the respondent’s impairments prevented of restricted her from performing tasks that are of central importance to most people’s daily life.
The ADA requires that an impairment substantially limit an individual in the performance of one of more major life activities for the impairment to qualify as a disability.
The phrase, “major life activities” refers to those activities that are of central importance to daily life.
In order for performing manual tasks to fit into this category, a category that includes such basic abilities as walking, seeing, and hearing, the manual tasks and questions must be central to daily life.
The Court of Appeals erred by focusing only on respondent’s inability to perform manual tasks associated with her particular job.
In this case, repetitive work with hands and arms extended at or above shoulder levels for extended periods of time which was the manual tasks relied on by the Court of Appeals is not an important of most people’s daily lives.
The Court therefore should not have considered that inability as sufficient proof that she was substantially limited in performing manual tasks and the Court of Appeals should not have disregarded the evidence that respondent could tend to her personal hygiene and carry out personal or household chores.
These are the types of manual tasks of central importance to people’s daily life and should have been part of the court’s analysis.
On ths record, it was inappropriate for the Court of Appeals to grant partial summary judgment to respondent on the issue of whether she was substantially limited in performing manual tasks.
We reversed the judgment and remand the case of the Court of Appeals.
The opinion of the court is unanimous.