Toyota Motor Manufacturing v. Williams
Encyclopedia
Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, 534 U.S. 184
(2002) was a case in which the Supreme Court of the United States
interpreted the meaning of the phrase "substantially impairs" as used in the Americans with Disabilities Act of 1990
. It reversed the decision by the Court of Appeals to grant a partial summary judgment
in favor of the respondent, Ella Williams that qualified her inability to perform manual job-related tasks as a disability
.
and bilateral tendinitis. Her personal physician placed her on certain restrictions regarding her movements, and Toyota assigned her to various alternative jobs to accommodate her limitations. When Williams missed work for medical reasons due to job-related tasks, she filed a claim the Kentucky Workers’ Compensation Act. Ky. Rev. Stat. Ann. §342.0011 et seq. (1997 and Supp. 2000). This claim was settled between the parties, and Williams returned to work. However, she remained dissatisfied with Toyota's efforts to accommodate her work restrictions and brought action in the United States District Court for the Eastern District of Kentucky
claiming that Toyota had refused to accommodate her disability, a suit that was again settled and she returned to work as a Quality Control Inspection Operations (QCIO) worker which involved visual inspection of vehicles. Both parties agreed that she was able to perform these duties satisfactorily. However, in the fall of 1996, the job duties changed and Williams was required to perform some additional physical tasks, which caused Williams difficulty.
Although the parties disagree on the facts from this point on, in any case Williams was restricted by her physician from work of any kind; she was fired, and eventually she sued her former employer for failing to accommodate her disability reasonably and for terminating her employment.
(ADA), 42 U. S. C. §12112(b)(5)(A). Upon Toyota's appeal, the District Court issued a summary judgment
that the Williams's impairment did not qualify as a "disability" under the ADA because her disability did not "substantially limit" any "major life activity" §12102(2)(A), and that there was no evidence that she possessed a record of such disabilities.
Under ADA, a "major life activity" includes actions of daily living such as "walking, seeing, hearing, learning, and working", not limitations specific to job-related tasks.
The Sixth Circuit Court of Appeals reversed this summary judgment, ruling that Williams's impairments substantially limited her ability to perform manual tasks and considered this a limitation in a "major life activity". To demonstrate this disability, Williams showed that her manual disability extended to a "class" of manual activities that directly related to her ability to perform specific work tasks such as repetitive activities, the gripping of certain tools, and performing tasks while in a particular posture for extended time period. The court specifically disregarded evidence that she was able to perform personal care tasks and tasks involving household chores as irrelevant to its finding. It granted her a partial summary judgment that she was disabled under the ADA.
The case was appealed to the Supreme Court. Future Chief Justice
John Roberts argued the case for petitioner Toyota.
issued the opinion.
The "major life activity" definition in evaluating the performance of manual tasks focuses the inquiry on whether Williams was unable to perform a range of tasks central to most people in carrying out the activities of daily living. The issue is not whether Williams was unable to perform her specific job tasks. Therefore, the determination of whether an impairment rises to the level of a disability is not limited to activities in the workplace solely, but rather to manual tasks in life in general. When the Supreme Court applied this standard, it found that the Court of Appeals had incorrectly determined the presence of a disability because it relied solely on her inability to perform specific manual work tasks which was insufficient in proving the presence of a disability. The Court of Appeals should have taken into account the evidence presented that Williams retained the ability to do personal tasks and household chores, such activities being the nature of tasks most people do in their daily lives, and placed too much emphasis on her job disability. Since the evidence showed that Williams was performing normal daily tasks, it ruled that the Court of Appeals erred when it found Williams to be disabled.
Therefore, the Court of Appeals’ judgment granting partial summary judgment to Williams was reversed and the case was remanded back to the District Court of Appeals for further deliberations consistent with the Supreme Court's opinion.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2002) was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
interpreted the meaning of the phrase "substantially impairs" as used in the Americans with Disabilities Act of 1990
Americans with Disabilities Act of 1990
The Americans with Disabilities Act of 1990 is a law that was enacted by the U.S. Congress in 1990. It was signed into law on July 26, 1990, by President George H. W. Bush, and later amended with changes effective January 1, 2009....
. It reversed the decision by the Court of Appeals to grant a partial summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
in favor of the respondent, Ella Williams that qualified her inability to perform manual job-related tasks as a disability
Disability
A disability may be physical, cognitive, mental, sensory, emotional, developmental or some combination of these.Many people would rather be referred to as a person with a disability instead of handicapped...
.
Facts of case
The respondent, Ella Williams, an automobile assembly line worker, was first employed by the petitioner, Toyota Motor Manufacturing, Kentucky, Inc., at Toyota's automobile manufacturing plant in Georgetown, Kentucky, in 1990 where she worked on an assembly line using pneumatic tools. Eventually she began to experience pain in her hands, wrists, and arms, for which she sought treatment and was diagnosed with bilateral carpal tunnel syndromeCarpal tunnel syndrome
Carpal Tunnel Syndrome is an entrapment idiopathic median neuropathy, causing paresthesia, pain, and other symptoms in the distribution of the median nerve due to its compression at the wrist in the carpal tunnel. The pathophysiology is not completely understood but can be considered compression...
and bilateral tendinitis. Her personal physician placed her on certain restrictions regarding her movements, and Toyota assigned her to various alternative jobs to accommodate her limitations. When Williams missed work for medical reasons due to job-related tasks, she filed a claim the Kentucky Workers’ Compensation Act. Ky. Rev. Stat. Ann. §342.0011 et seq. (1997 and Supp. 2000). This claim was settled between the parties, and Williams returned to work. However, she remained dissatisfied with Toyota's efforts to accommodate her work restrictions and brought action in the United States District Court for the Eastern District of Kentucky
United States District Court for the Eastern District of Kentucky
The United States District Court for the Eastern District of Kentucky is the Federal district court whose jurisdiction comprises approximately the Eastern half of the state of Kentucky....
claiming that Toyota had refused to accommodate her disability, a suit that was again settled and she returned to work as a Quality Control Inspection Operations (QCIO) worker which involved visual inspection of vehicles. Both parties agreed that she was able to perform these duties satisfactorily. However, in the fall of 1996, the job duties changed and Williams was required to perform some additional physical tasks, which caused Williams difficulty.
Although the parties disagree on the facts from this point on, in any case Williams was restricted by her physician from work of any kind; she was fired, and eventually she sued her former employer for failing to accommodate her disability reasonably and for terminating her employment.
Legal history
Williams claimed to be disabled and unable to perform her job at Toyota because of carpal tunnel syndrome and related problems. She successfully sued Toyota Motor Manufacturing, Kentucky, Inc. for failure to provide "reasonable accommodations" as required by the Americans with Disabilities Act of 1990Americans with Disabilities Act of 1990
The Americans with Disabilities Act of 1990 is a law that was enacted by the U.S. Congress in 1990. It was signed into law on July 26, 1990, by President George H. W. Bush, and later amended with changes effective January 1, 2009....
(ADA), 42 U. S. C. §12112(b)(5)(A). Upon Toyota's appeal, the District Court issued a summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
that the Williams's impairment did not qualify as a "disability" under the ADA because her disability did not "substantially limit" any "major life activity" §12102(2)(A), and that there was no evidence that she possessed a record of such disabilities.
Under ADA, a "major life activity" includes actions of daily living such as "walking, seeing, hearing, learning, and working", not limitations specific to job-related tasks.
The Sixth Circuit Court of Appeals reversed this summary judgment, ruling that Williams's impairments substantially limited her ability to perform manual tasks and considered this a limitation in a "major life activity". To demonstrate this disability, Williams showed that her manual disability extended to a "class" of manual activities that directly related to her ability to perform specific work tasks such as repetitive activities, the gripping of certain tools, and performing tasks while in a particular posture for extended time period. The court specifically disregarded evidence that she was able to perform personal care tasks and tasks involving household chores as irrelevant to its finding. It granted her a partial summary judgment that she was disabled under the ADA.
The case was appealed to the Supreme Court. Future Chief Justice
Chief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
John Roberts argued the case for petitioner Toyota.
Decision
Writing for the court, Justice Sandra Day O'ConnorSandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
issued the opinion.
The "major life activity" definition in evaluating the performance of manual tasks focuses the inquiry on whether Williams was unable to perform a range of tasks central to most people in carrying out the activities of daily living. The issue is not whether Williams was unable to perform her specific job tasks. Therefore, the determination of whether an impairment rises to the level of a disability is not limited to activities in the workplace solely, but rather to manual tasks in life in general. When the Supreme Court applied this standard, it found that the Court of Appeals had incorrectly determined the presence of a disability because it relied solely on her inability to perform specific manual work tasks which was insufficient in proving the presence of a disability. The Court of Appeals should have taken into account the evidence presented that Williams retained the ability to do personal tasks and household chores, such activities being the nature of tasks most people do in their daily lives, and placed too much emphasis on her job disability. Since the evidence showed that Williams was performing normal daily tasks, it ruled that the Court of Appeals erred when it found Williams to be disabled.
Therefore, the Court of Appeals’ judgment granting partial summary judgment to Williams was reversed and the case was remanded back to the District Court of Appeals for further deliberations consistent with the Supreme Court's opinion.