by Melanie Brunson
On January 8, 2002, the U.S. Supreme Court handed down a unanimous decision in yet another case involving provisions of the Americans with Disabilities Act. The issue in this case, Toyota Motor Manufacturing of Ky. Inc. v. Williams, was whether Williams, an employee in Toyota's Kentucky plant, was a qualified person with a disability, as defined by the ADA, and therefore, entitled to accommodation in the form of a change in her job duties under Title III of the act.
Ella Williams, who began working as an assembly line worker at Toyota's plant in Georgetown, Ky., in 1990, developed carpal tunnel syndrome and tendinitis in her hands and arms as a result of using pneumatic tools. Her doctor recommended a variety of restrictions, including no repetitive work with hands and arms extended at or above shoulder level for extended periods of time. Toyota accommodated these restrictions by assigning her to the body paint inspection group, where persons with disabilities or medical restrictions were placed. However, after she had worked in that group for almost three years, Toyota added new duties to her job, including gripping a wooden-handled sponge to wipe down cars. Williams stated that the carpal tunnel syndrome and tendinitis in her hands and arms then flared up again even more severely, and she also developed tendinitis in her shoulders and neck. She asked that she be allowed to return to performing only paint inspection duties, but Toyota refused to grant this request. Eventually, she was fired after not showing up for work and a lawsuit followed.
The U.S. Court of Appeals for the Sixth Circuit found that she was disabled, stating that despite Williams' testimony that she could brush her teeth, wash her face, bathe, tend her flower garden, fix breakfast, do laundry, and pick up around the house, she was still substantially limited in her ability to perform manual tasks related to her work, and that limitation was sufficient to allow her to bring suit against Toyota for violating Title III of the ADA. Toyota appealed to the U.S. Supreme Court.
The Supreme Court reversed the decision of the Sixth Circuit finding that the lower court had used the wrong standard to determine whether Williams was a person with a disability according to the standard found in the ADA. Writing for the unanimous court, Justice O'Connor points out that the ADA defines disability as an impairment that substantially limits the ability of an individual to perform one or more major life activities. "Substantially in the phrase 'substantially limits' suggests considerable or to a large degree, and thus clearly precludes impairments that interfere in only a minor way with performing manual tasks. Moreover, because major means important, '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 in question must be central to daily life. If each of the tasks included in the major life activity of performing manual tasks does not independently qualify as a major life activity, then together they must do so."
The court notes that it is not sufficient that the manual tasks are performed only at work, because the ADA applies to a variety of situations that are not work-related, such as access to public accommodations and transportation. The definition of disability then must be broad enough to encompass all of an individual's life activities. In this case, therefore, the high court held that the lower court erred in failing to ask whether the respondent's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives, and thus did not properly determine whether she met the definition of disability found in the ADA. Justice O'Connor wrote, "Household chores, bathing, and brushing one's teeth are among the types of manual tasks of central importance to people's daily lives, so the Sixth Circuit should not have disregarded respondent's ability to do these activities." The case was sent back to the lower courts for reconsideration under the proper standard of review.
This case does not stand for the proposition that carpal tunnel syndrome is not a disability. It simply states that in order for it to be a disability, this impairment must have an impact on one's ability to perform a variety of tasks including those that are major activities of daily life. When an individual case is evaluated according to this standard, it could quite easily rise to the level of a disability. What we have here is a strict interpretation of the language of the ADA itself. As such, it has narrowed the class of covered individuals somewhat, but not enough to seriously undermine the integrity of the law, as some had feared it would.
There are a number of other ADA cases pending before this court and we will publish details of the decisions in those cases as soon as they are available. In the meantime, rest assured that the right to reasonable accommodation in the workplace provided for in Title II of the ADA stands intact for qualified persons with disabilities across the United States.