Greenberg Traurig Alert

In Landmark ADA Case, U.S. Supreme Court Clarifies What Constitutes a "Substantial Limitation" in the Major Life Activity of Performing Manual Tasks

January 2002
By John Scalia, Esq. and Julia Perkins, Esq., Greenberg Traurig

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On January 8, 2002, in an unanimous decision, the United States Supreme Court addressed the important employment law issue of what an employee must demonstrate to show that he or she is substantially limited in the major life activity of performing manual tasks in order to be considered disabled under the Americans with Disabilities Act.

"According to the Court, the material issue [is] "whether the [employee] is unable to perform the variety of tasks central to most people’s daily lives..."

In Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, U.S. No. 00-1089 (1/8/02), the Court interpreted the broad terms of the ADA, which obligates employers to make reasonable accommodations for disabled employees. The Court held that an employee is substantially limited in performing manual tasks when he or she has an impairment that "prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives." In so holding, the Court sends the message to all courts interpreting the ADA that an employee does not receive ADA protection by merely showing that he or she is unable to perform repetitive tasks with respect to his or her job duties. Courts now must require an employee to establish that the repetitive activities in his or her daily life are also substantially affected by the impairment.

The Williams case involved the following facts. Ms. Ella Williams worked at a Toyota Motor Corporation assembly plant. Ms. Williams developed carpal tunnel syndrome, a repetitive-stress injury resulting in pain in her arms and hands. Her physician placed her on permanent work restrictions that included restrictions on lifting, "overhead work," and constant repetitive extension of her wrists or elbows. In light of these restrictions, Toyota transferred Ms. Williams to a job within the facility inspecting the paint on cars. Toyota subsequently expanded Ms. Williams’ duties to include wiping the cars with oil as they passed by at the rate of a car a minute. Ms. Williams requested that Toyota accommodate her physical condition by returning her to the original duties in the new position so that she would not have to perform the repetitive wiping of the oil on the cars. No accommodation was made and Ms. Williams subsequently was terminated for poor attendance.

Ms. Williams filed suit, alleging that Toyota violated the ADA by failing to reasonably accommodate her disability and by terminating her employment. The U.S. District Court granted summary judgment in Toyota’s favor, finding in relevant part that Ms. Williams was not disabled under the ADA. The Court of Appeals for the Sixth Circuit reversed the District Court’s ruling. The Sixth Circuit held that Ms. Williams had sufficiently demonstrated she was disabled under the ADA by demonstrating she was substantially limited in the performance of her job duties. The Sixth Circuit therefore held that Ms. Williams was entitled to partial judgment in her favor as to the issue of whether she was disabled under the ADA. However, the United States Supreme Court accepted review of the case, and concluded that the Sixth Circuit Court of Appeals had not used the proper standard for assessing whether an individual is substantially limited in performing manual tasks. The Supreme Court reversed the Sixth Circuit’s partial summary judgment in Ms. Williams’ favor, and remanded the case for further proceedings.

In reaching its decision in Williams, the Supreme Court looked to the legislative history of the ADA, which makes mention of an estimated 43 million Americans who have a physical or mental disability. The Court reasoned that if Congress had intended the ADA to cover everyone with a physical impairment that precluded the performance of an isolated manual task, the number of disabled Americans cited in the legislative history would have been much higher. According to the Court, the material issue was "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." The Court determined that the repetitive work that resulted in Ms. Williams’ impairment was not an important part of most people’s daily lives. "Household chores, bathing and brushing one’s teeth" are the types of activities that should be considered in deciding whether an employee is substantially limited in performing manual tasks. Because the Court of Appeals disregarded all non-workplace evidence in reaching its determination, the matter was remanded for further consideration in light of the Supreme Court’s decision.

The Williams decision is a significant judicial development in the area of ADA law. It is the latest in a series of United States Supreme Court decisions defining the scope of the ADA and giving much-needed guidance to employers and employees alike. As a result of Williams, when claiming to be disabled because of a substantial limitation of an ability to perform manual tasks, an employee can no longer rely solely on evidence showing he or she is unable to perform repetitive tasks within the workplace in order to qualify for protection under the ADA. It is now clear that the employee must also show that the impairment substantially affects his or her life outside of the workplace. Furthermore, the Court cautioned that the Act’s essential definitional terms, "substantially limits" and "major life activities," need to be interpreted strictly in order to create a "demanding standard for qualifying as disabled." Finally, as in recent cases, the Court stressed the importance of an individual, case-by-case determination of disability rather than a conclusion based on a medical diagnosis.

On a practical level for employers, the Supreme Court’s decision in Williams points out the importance of the interactive process. Employers should engage employees in meaningful dialog to determine the basis for requests for accommodation. Particularly with respect to an accommodation request for an ailment affecting the ability to perform manual tasks, employers should consider the severity of the ailment on the employee (for example, as noted by the Court, the effect of carpal tunnel syndrome on individuals runs the gamut) and how the ailment affects not just the performance of the person’s job, but, more importantly, the daily, repetitive tasks central to most people’s lives.

© 2002 Greenberg Traurig

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