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
American Law Division
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
42 U.S.C. §12102(b)(1).
42 U.S.C. §12112(b)(5)(A).
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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
42 U.S.C. § 12102(2).
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).
224 F.3d 840 (6th Cir. 2000).
224 F.3d 840, 843 (6th Cir. 2000).
See Sutton v. United Airlines, 527 U.S. 471, 479 (1999).
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
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).
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.”
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
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.
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.
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).
See “ADA: High Court Limits Definition of Disability Under Law,” American Health Line (Jan.
Id.; “National Council on Disability Deeply Troubled by Supreme Court Ruling Limiting Scope
of Disability Law,” U.S. Newswire January 8, 2002.
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).
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.
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.
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