Toyota Motor Mfg., Ky., Inc. v. Williams
Annotate this Case
534 U.S. 184 (2002)
OCTOBER TERM, 2001
TOYOTA MOTOR MANUFACTURING, KENTUCKY, INC. v. WILLIAMS
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
No. 00-1089. Argued November 7, 200l-Decided January 8, 2002
Claiming to be unable to perform her automobile assembly line job because she was disabled by carpal tunnel syndrome and related impairments, respondent sued petitioner, her former employer, for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA), 42 U. S. C. § 12112(b)(5)(A). The District Court granted petitioner summary judgment, holding that respondent's impairment did not qualify as a "disability" under the ADA because it had not "substantially limit[ed]" any "major life activit[y]," § 12102(2)(A), and that there was no evidence that respondent had had a record of a substantially limiting impairment or that petitioner had regarded her as having such an impairment. The Sixth Circuit reversed, finding that the impairments substantially limited respondent in the major life activity of performing manual tasks. In order to demonstrate that she was so limited, said the court, respondent had to show that her manual disability involved a "class" of manual activities affecting the ability to perform tasks at work. Respondent satisfied this test, according to the court, 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. In reaching this conclusion, the court found that evidence that respondent could tend to her personal hygiene and carry out personal or household chores did not affect a determination that her impairments substantially limited her ability to perform the range of manual tasks associated with an assembly line job. The court granted respondent partial summary judgment on the issue of whether she was disabled under the ADA.
Held: The Sixth Circuit did not apply the proper standard in determining that respondent was disabled under the ADA because it analyzed only a limited class of manual tasks and failed to ask whether respondent's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives. Pp. 193-203.
(a) The Court's consideration of what an individual must prove to demonstrate a substantial limitation in the major life activity of performing manual tasks is guided by the ADA's disability definition.
"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. Cf. Albertson's, Inc. v. Kirkingburg, 527 U. S. 555, 565. 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, the tasks in question must be central to daily life. To be substantially limited in the specific major life activity of performing manual tasks, therefore, 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 impairment's impact must also be permanent or long term. See 29 CFR §§ 1630.2(j)(2)(ii)-(iii).
It is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment. Instead, the ADA requires them to offer evidence that the extent of the limitation caused by their impairment in terms of their own experience is substantial. 527 U. S., at 567. That the ADA defines "disability" "with respect to an individual," § 12102(2), makes clear that Congress intended the existence of a disability to be determined in such a case-by-case manner. See, e. g., Sutton v. United Air Lines, Inc., 527 U. S. 471, 483. An individualized assessment of the effect of an impairment is particularly necessary when the impairment is one such as carpal tunnel syndrome, in which symptoms vary widely from person to person. Pp. 196-199.
(b) The Sixth Circuit erred in suggesting that, in order to prove a substantial limitation in the major life activity of performing manual tasks, a plaintiff must show that her manual disability involves a "class" of manual activities, and that those activities affect the ability to perform tasks at work. Nothing in the ADA's text, this Court's opinions, or the regulations suggests that a class-based framework should apply outside the context of the major life activity of working. While the Sixth Circuit addressed the different major life activity of performing manual tasks, its analysis erroneously circumvented Sutton, supra, at 491, by focusing on respondent's inability to perform manual tasks associated only with her job. Rather, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives. Also without support is the Sixth Circuit's assertion that the question of whether an impairment constitutes a disability is to be answered only by analyzing the impairment's effect in the workplace. That the ADA's "disability" definition applies not only to the portion of the ADA dealing with employment, but also to the other provisions dealing with public transportation and public accommoda-
Disclaimer: Official Supreme Court case law is only found in the print version of the United States Reports. Justia case law is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.