American Journal of Law & Medicine

Disability law: substantial limitations under the Americans with Disabilities Act.

Toyota Motor Manufacturing, Kentucky, Inc. v. Williams (1)--In an unanimous decision, the Supreme Court held that the proper standard for assessing whether an individual is substantially limited in performing manual tasks for purposes of the Americans with Disabilities Act of 1990 (2) (ADA), requires that the individual have a permanent or long-term impairment which "prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives." (3) The inquiry focuses on the ability of an individual to perform tasks essential to most people's daily lives, rather than tasks associated with the individual's employment.

Respondent Ella Williams worked at petitioner's Toyota Motor Manufacturing plant from August 1990 to December 1996. The tools that Williams initially worked with at Toyota caused pain in her hands, wrists and arms, and she was eventually diagnosed at Toyota's in-house medical service with "bilateral carpal tunnel syndrome and bilateral tendinitis." (4) Williams's personal physician then issued restrictions on the type of work Williams could perform, specifically recommending that she avoid lifting objects in excess of twenty pounds; frequently lifting or carrying objects weighing up to ten pounds; constant, repetitive, flexing or extending of her wrists or elbows; and performing overhead work or using vibratory or pneumatic tools. (5) As a result of these restrictions, Toyota modified Williams's work duties for the next two years. However, Williams still took medical leave and eventually filed a claim under the Kentucky Workers' Compensation Act, which resulted in a settlement and her return to work. (6) Dissatisfied with Toyota's efforts at accommodation, Williams eventually filed suit in the federal district court in Kentucky for ADA violations. This suit, too, was settled, and in December 1993, Williams returned to work, where she was assigned to the Quality Control Inspection Operations (QCIO) team. This group is responsible for four processes: "(1) `assembly paint'; (2) `paint second inspection'; (3) `shell body audit'; and (4) `ED surface repair.'" (7) For over two years Williams performed, without difficulty, the first two of these duties. The first required visual inspections and was modified during her tenure to include little to no manual tasks; the other required wiping cars with gloved hands as the cars moved along a conveyor belt.

In 1996, Toyota announced that members of the QCIO team were to begin rotating through the four processes. …

Log in to your account to read this article – and millions more.