The Americans with Disabilities Act: Toyota Motor Manufacturing v. Williams

The Supreme Court, in Toyota Motor Manufacturing v. Williams, held that to be an individual with a disability under the Americans with Disabilities Act (ADA) an individual must have substantial limitations on abilities that are central to daily life, rather than only to those abilities used in the workplace. In an unanimous opinion written by Justice O'Connor, the Court interpreted the definition of individual with disability narrowly to exclude individuals who are limited only in the performance of manual tasks associated with their job. This report will briefly discuss Williams and its implications for the ADA. For a more detailed discussion of the ADA see CRS Report 98-921 , The Americans with Disabilities Act (ADA): Statutory Language and Recent Issues.
This report will not be updated.

Order Code RS21105 January 15, 2002 CRS Report for Congress Received through the CRS Web The Americans with Disabilities Act: Toyota Motor Manufacturing v. Williams name redacted Legislative Attorney American Law Division Summary The Supreme Court, in Toyota Motor Manufacturing v. Williams, held that to be an individual with a disability under the Americans with Disabilities Act (ADA) an individual must have substantial limitations on abilities that are central to daily life, rather than only to those abilities used in the workplace. In an unanimous opinion written by Justice O’Connor, the Court interpreted the definition of individual with disability narrowly to exclude individuals who are limited only in the performance of manual tasks associated with their job. This report will briefly discuss Williams and its implications for the ADA. For a more detailed discussion of the ADA see CRS Report 98-921, The Americans with Disabilities Act (ADA): Statutory Language and Recent Issues. This report will not be updated. Background. The Americans with Disabilities Act, ADA, 42 U.S.C. §§12101 et seq., has often been described as the most sweeping nondiscrimination legislation since the Civil Rights Act of 1964. It provides broad nondiscrimination protection for individuals with disabilities in employment, public services, public accommodation and services operated by private entities, transportation, and telecommunications. As stated in the Act, its purpose is “to provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.”1 With regard to employment, the ADA requires that employers provide “reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless such covered entity can demonstrate that the accommodation would impose an undue hardship.”2 The term “disability,” with respect to an individual, is defined as “(A) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (B) a record of such an 1 2 42 U.S.C. §12102(b)(1). 42 U.S.C. §12112(b)(5)(A). Congressional Research Service ˜ The Library of Congress CRS-2 impairment; or (C) being regarded as having such an impairment.”3 Several Supreme Court cases have examined the definition of disability4 but the Court had not examined the meaning of “substantially limits” until Williams. Williams involved an employee with carpal tunnel syndrome and tendinitis in her hands, arms, and shoulders which she alleged substantially limited her ability to perform manual tasks, housework, gardening, playing with her children, lifting, and working. The district court rejected her arguments that gardening, doing housework, and playing with children are major life activities and found that, although manual tasks, lifting, and working are major life activities, the evidence was insufficient to conclude that the plaintiff, Mrs. Williams, had been substantially limited in these activities. The plaintiff appealed the ruling regarding the manual tasks, lifting, and working but did not appeal the ruling regarding gardening, housework, and playing with children. The Court of Appeals for the Sixth Circuit reversed, holding that in order for Mrs. Williams to demonstrate that she was disabled due to a substantial limitation in the ability to perform manual tasks at the time of her accommodation request, she had to show that her manual disability involved a class of manual activities that affected her ability to perform tasks at work.5 The Sixth Circuit found that this test was met stating that Mrs. Williams’ ailments were “analogous to having missing, damaged or deformed limbs that prevent her from doing the tasks associated with certain types of manual assembly line jobs....”6 and noted that the fact that she can perform a range of isolated, non-repetitive manual tasks such as carrying out personal or household chores did not affect this determination. Due to this holding, the Court of Appeals found it did not need to determine whether Mrs. Williams had been substantially limited in the major life activities of lifting or working. Supreme Court’s Opinion in Toyota Motor Manufacturing v. Williams. The Supreme Court granted certiorari to determine whether an impairment that precluded an individual from performing only a limited number of tasks associated with a specific job qualifies the individual for ADA coverage. The Court unanimously reversed the sixth circuit, holding that to have a disability, an individual must have substantial limitations that are central to daily life, not just limited to a particular job. The case was remanded for consideration of the arguments not considered by the court of appeals. Justice O’Connor began her analysis with a discussion of the statutory provisions and regulations. As in previous cases,7 the Supreme Court emphasized that the regulations promulgated by the Equal Employment Opportunity Commission (EEOC) regarding the definition of disability are not necessarily authoritative since the statutory section containing the definition does not give regulatory authority to any agency. However, since 3 42 U.S.C. § 12102(2). 4 Bragdon v. Abbott, 524 U.S. 624 (1998)(asymptomatic HIV infection was a disability under the ADA); Sutton v. United Airlines, 527 U.S. 471 (1999)(a correctable vision impairment was not a disability); Murphy v. United Parcel Service, 527 U.S. 516 (1999)(an individual with high blood pressure was not an individual with a disability since he experienced no substantial limitations in major life activities while taking his medication). 5 224 F.3d 840 (6th Cir. 2000). 6 224 F.3d 840, 843 (6th Cir. 2000). 7 See Sutton v. United Airlines, 527 U.S. 471, 479 (1999). CRS-3 this issue was not raised, the Court assumed, without deciding, that the EEOC regulations were reasonable.8 The Court also declined to decide the issue of whether working could be considered a major life activity. The Court noted that the central question in the case was whether the plaintiff was an individual with a disability under the first prong of the definition; that is, whether she had a physical or mental impairment that substantially limits a major life activity. There was no dispute regarding that fact that the plaintiff’s conditions were physical impairments. The difference of opinion involved whether these impairments substantially limited the plaintiff in the major life activity of performing manual tasks. In order to resolve this issue, Justice O’Connor determined that the word substantial “clearly precluded impairments that interfere in only a minor way with the performance of manual tasks.” Similarly, the Court found that the term “major life activity” “refers to those activities that are of central importance to daily life.” Finding that these terms are to be “interpreted strictly,”9 the Court held that “to be substantially limited in 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.” Significantly, the Court also stated that “[t]he impairment’s impact must also be permanent or long-term.” In support of this later statement, the opinion referenced the EEOC’s regulations which state in relevant, and apparently contradictory, part: “The following factors should be considered in determining whether an individual is substantially limited in a major life activity....(ii) the duration or expected duration of the impairment; and (iii) The permanent or long term impact, or the expected permanent or long term impact of or resulting from the impairment.”10 The EEOC has also issued guidance on the definition of disability which states “[a]lthough very short-term, temporary restrictions generally are not substantially limiting, an impairment does not have to be permanent to rise to the level of a disability. Temporary impairments that take significantly longer than normal to heal, long-term impairments of indefinite duration may be disabilities if they are severe.”11 8 The Court also examined the regulations regarding the definition of disability promulgated under section 504 of the Rehabilitation Act, 29 U.S.C. §794, as a potential source of interpretation since Congress drew the ADA’s definition of disability from that of section 504 and Congress stated in the ADA that nothing in the ADA shall be construed to apply a lesser standard than under title V of the Rehabilitation Act. 42 U.S.C. §12201(a). 9 Confirmation of the need for strict interpretation was found by the Court in the ADA’s statement of findings and purposes where Congress stated that “some 43,000,000 Americans have one or more physical or mental disabilities.” [42 U.S.C. §12101(a)(1)] Justice O’Connor observed that “if Congress had intended everyone with a physical impairment that precluded the performance of some isolated, unimportant, or particularly difficult manual task to qualify as disabled, the number of disabled Americans would surely have been much higher.” 10 11 29 C.F.R. §1630.2(j)(2)(ii)-(iii)(emphasis added). EEOC Compliance Manual, Section 902. Reproduced by BNA, Americans with Disabilities Act Manual 70:1131. The EEOC also provided a number of examples where a temporary condition would be a disability under the ADA. For example, a person “has nodes on his vocal chords. His doctor has told (him) that he must rest his vocal chords and that he will lose his ability to speak unless he refrains from talking for more than one hour per day for the next one-and-one half years. If (he) follows his doctor’s advise, his vocal chords will heal and he will have full use (continued...) CRS-4 The Supreme Court’s opinion also emphasized the need for an individualized assessment of the effect of the impairment. Justice O’Connor found it insufficient to merely submit evidence of a medical diagnosis of an impairment; rather, the individual must offer evidence that the extent of the impairment in their own situation is substantial. This approach was described as particularly critical when the condition is one like carpal tunnel, where the symptoms vary widely from person to person. The Supreme Court found the reasoning flawed in the Court of Appeals’ analysis 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 these affect the ability to perform tasks at work. “When addressing the major life activity of performing manual tasks, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people’s daily lives, not whether the claimant is unable to perform the tasks associated with her specific job.” Justice O’Connor noted that “the manual tasks unique to any particular job are not necessarily important parts of most people’s lives. As a result, occupation-specific tasks may have only limited relevance to the manual task inquiry.” The Court of Appeals, Justice O’Connor observed, disregarded the fact that the plaintiff can tend to her personal hygiene and perform household chores. These facts were seen as key to the finding that the court of appeals decision was incorrect. The case was then remanded. Implications of Williams. The Supreme Court’s decision in Toyota Motor Manufacturing v. Williams continues the trend of the Court to limit the reach of the definition of disability in the ADA.12 Falling under the definition of disability is the first hurdle plaintiffs must overcome to be successful in an ADA claim and limiting the reach of the definition will render success for a plaintiff in an ADA action less likely. Employers generally have praised the Court’s decision in Williams, stating that it provides needed clarity to the definition of disability.13 Disability advocates have generally bemoaned the limited interpretation.14 Another commentator argued that a ruling for Mrs. Williams would have blurred the line between the ADA and workplace compensation injuries and required employers to provide jobs tailored to the individual at a significant cost while the decision “will actually benefit disabled workers by drawing clear guidelines for all businesses to follow....”15. 11 (...continued) of his voice....(His) impairment will last for many months and will significantly restrict his ability to speak during that time...(and he) has a disability. At 70:1145. 12 Some state statutes may have different standards. See Mary Ann Milbourn, “ADA Ruling has Little Impact Here: Work State Law Runs Counter to High Court Decision that Limits Carpal Tunnel Syndrome,” Orange County Register (January 9, 2002). 13 See “ADA: High Court Limits Definition of Disability Under Law,” American Health Line (Jan. 9, 2002). 14 Id.; “National Council on Disability Deeply Troubled by Supreme Court Ruling Limiting Scope of Disability Law,” U.S. Newswire January 8, 2002. 15 Suzanne Robitaille, “A Victory in Disguise for the Disabled; Though Advocates Decry the Supreme Court’s New Ruling on the ADA, It’s Really a Boon to Employers and Employees Alike,” Business Week Online (January 11, 2002). CRS-5 The decision was closely watched in part because it involved carpal tunnel syndrome, a condition that has become increasingly prevalent. Repetitive motion injuries have been the subject of controversial regulations on workplace safety which were eliminated by congressional action in 2001.16 The Supreme Court did not eliminate carpal tunnel injuries from ever meeting the definition of disability, however. Rather, the Court emphasized the need to examine each case individually “given these large potential differences in the severity and duration of effects of carpal tunnel syndrome.” Certain other implications deserve mention. Justice O’Connor specifically stated: “we therefore hold that to be substantially limited in 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 impairment’s impact must also be permanent or long-term.” The statement that an impairment must be permanent or long-term differs from the EEOC requirement that the long term impact of an impairment is one factor that should be considered and will have implications for the ADA coverage of individuals without permanent disabilities. The Supreme Court’s decision also left undecided the weight which should be accorded the EEOC regulations on the definition of disability. Similarly, the Court also declined to decide whether work was a major life activity. 16 S.J. Res. 6, 107th Cong. For a discussion of this issue see Edward Rappaport, “Ergonomics in the Workplace: Is it Time for an OSHA Standard?” CRS Rep. 97-724. EveryCRSReport.com The Congressional Research Service (CRS) is a federal legislative branch agency, housed inside the Library of Congress, charged with providing the United States Congress non-partisan advice on issues that may come before Congress. 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