On January 8, 2002, the United States Supreme Court reached a landmark decision in the ongoing “debate over definitions” that is the Americans with Disabilities Act.
In Toyota Motor Manufacturing, Kentucky, Inc., v. Williams, Justice Sandra Day O’Connor delivered the opinion for a unanimous Court. O’Connor helped define what sorts of disabilities properly trigger an ADA complaint when she wrote,
” … the Court of Appeals appears to have disregarded the very type of evidence that it should have focused upon. It treated as irrelevant ‘[t]he fact that [respondent] can … ten[d] to her personal hygiene [and] carr[y] out personal or household chores.’ Ibid. Yet household chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives, and should have been part of the assessment of whether respondent was substantially limited in performing manual tasks.”
The suit was brought by Ella Williams, who worked on a Toyota auto assembly line, using pneumatic tools beginning in 1990. She developed carpal tunnel syndrome in both wrists. When the condition was brought to Toyota’s attention, Williams was assigned to “various modified-duty jobs.”
Williams nevertheless filed an ADA suit against Toyota. That matter was settled, and she was placed in and performed a job satisfactory to both her and Toyota.
A couple of years later, Toyota changed her duties. She developed additional medical problems affecting her upper body and extremities. Advised by her doctor not to do any kind of work, she last worked on December 6, 1996. On January 27, 1997, she received a letter from Toyota that terminated her employment, citing her poor attendance record.
Williams responded by filing a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC). After receiving from the EEOC a “right to sue” letter, she filed suit against Toyota in the United States District Court for the Eastern District of Kentucky, alleging Toyota had violated the ADA and the Kentucky Civil Rights Act by failing to reasonably accommodate her disability and by terminating her employment.
When the District Court rejected her claim, Williams appealed. The Court of Appeals for the Sixth Circuit reversed the District Court, ruling in Williams’ favor because her medical conditions “prevent[ed] her from doing the tasks associated with certain types of manual assembly line jobs, manual product handling jobs and manual building trade jobs (painting, plumbing, roofing, etc.) that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time.”
Toyota appealed that decision to the U.S. Supreme Court, which granted certiorari in 2001.
Good Facts, Good Law
Lawyers often say that “bad facts make bad law.” Cases with odd, quirky factual scenarios can result in a decision that creates awkward precedent for subsequent cases with more straightforward facts.
The Toyota decision, by contrast, represents an example of good facts leading to good law. Even though Williams could not physically perform all of the manual tasks her job required (and indeed, there are probably many jobs she would not be able to perform), she had not established that she was substantially limited in performing “major life functions,” as required by the ADA.
While the health problems that affected her ability to do her job at Toyota prevented her from doing some common, non-work-related activities, the Supreme Court noted “… she could tend to her personal hygiene and carry out personal and household chores.” Accordingly, while her physical limitations may have prevented her from performing her job duties, they did not prevent her from doing many things that an average, healthy person can do.
As challenged as Ella Williams may have been by her medical conditions, she was not what the ADA’s original champions had in mind when they lobbied for and passed the Act in 1990.
One of the ADA’s principal advocates in the Senate was Bob Dole, a World War II soldier severely wounded in combat. Despite the loss of almost all function in his right arm, and the resulting ongoing pain, Dole graduated from law school and moved up the electoral ladder to the United States Senate.
Under the ADA, it is not enough for an employer not to discriminate against the person who can, despite physical limitations, fulfill the duties of his or her assigned job. The employer may be required to make changes in the workplace to ensure a person covered by the Act can do the job.
As the Supreme Court unanimously determined, the ADA applies when an employee has a “disability” that substantially limits one or more “major life activities.” A disability that prevents a person from doing his or her job does not necessarily trigger the ADA.
When President George H.W. Bush signed the Americans with Disabilities Act into law, he called it “… powerful in its simplicity.” The remarkable amount of litigation the Act has spawned would suggest he was overly optimistic.
But the High Court’s January decision is a dramatic step in the right direction. The message it sends is clear:
“[T]he 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. … [H]ousehold chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives, and [should be] part of the assessment of whether respondent was substantially limited in performing manual tasks.”
Dewey L. Crepeau is a private practice attorney in Columbia, Missouri focusing on workers’ compensation and Social Security Disability. He is a former assistant prosecuting attorney. Crepeau is also a contributing editor to Health Care News. He can be reached at [email protected].
For more information …
The full text of the U.S. Supreme Court’s decision in Toyota Motor Manufacturing, Kentucky, Inc., v. Williams is available on the Internet, in both HTML and PDF formats, at http://supct.law.cornell.edu/supct/html/00-1089.ZS.html.