Toyota Motor Mfg. v. Williams

534 U.S. 184 (2002) ; Clearinghouse Number: 54341

Description

Employee Who Cannot Perform Manual Tasks Necessary to Her Job But Can Perform Manual Tasks of Daily Living Is Not Disabled

Abstract

The Supreme Court held that, to be substantially limited in the specific major life activity of 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. Respondent employee is disabled from performing her automobile assembly job by carpal tunnel syndrome and related impairments. She claimed that petitioner, her former employer, failed to provide her with a reasonable accommodation as the Americans with Disabilities Act (ADA), 42 U.S.C. § 12112(b)(5)(A), required. The district court, holding that employee’s impairment did not qualify as a “disability” under the ADA because it did not substantially limit any major life activity, granted employer’s motion for summary judgment. The Sixth Circuit, reversing the district court, found that employee’s impairments substantially limited her in the major life activity of performing manual tasks. Reversing the Sixth Circuit, the Supreme Court held that the Sixth Circuit applied an improper standard in determining that employee was disabled because it analyzed only a limited class of manual tasks and failed to ask whether employee’s impairments prevented or restricted her from performing tasks that were of central importance to most people’s daily lives. The Court found that nothing in the ADA’s text, Supreme Court precedent, or regulations suggests that a class-based framework should apply outside the context of the major life activity of working. Moreover, the Court found that the definition of “disability” was intended to cover individuals with disabling impairments whether or not they had any connection to a workplace. The Court held that, because the manual tasks unique to any particular job were not necessarily important parts of most people’s lives, occupation-specific tasks might have only limited relevance to the manual task inquiry.

Additional Information

Attorney Information
Docket Date
2002-01-08 00:00:00+00:00

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