HR Law Case Study Example

Citation: Toyota Motor Mfg., Ky., Inc. v. Williams, 534 US 184 (2002).
Procedural History
Who is appealing on what issues?
The petitioner to the United States Supreme Court is Toyota Motor Manufacturing, Kentucky. They are appealing a decision by the Court of Appeals of the Sixth Circuit that Williams’ impairments substantially limited her in the major life activity of performing manual tasks, thus meeting the definition of “disabled” under the American Disabilities Act (ADA). In particular, they are asserting that the Court of Appeals applied an improper standard in making that determination.
What happened in the lower court?
Williams sued Toyota for allegedly failing to provide her with reasonable accommodation for her disability under the ADA. Her disability was claimed to be impairment caused by carpel tunnel syndrome and other related medical issues. Toyota was granted summary judgment in the District Court that Williams’ impairments did not substantially limit any of her major life activities. Williams appealed this decision to the Court of Appeals of the Sixth Circuit. The Court of Appeals of the Sixth Circuit reversed the District Court, finding that Williams’ impairments did substantially limit her in the major life activity of performing manual tasks. This allowed that court to grant partial summary judgment to Williams on the question whether or not she was “disabled” as defined by the ADA.
Legal Issue
The narrow legal issue is whether or not the Court of Appeals of the Sixth Circuit applied the proper standard when determining whether Williams was disabled. The standard it applied was that Williams had to show that “her manual disability involve[d] a class of manual activities affecting the ability to perform tasks at work” (224 F.3d 840, 843 (2000)).
Therefore, the question before the Supreme Court can also be stated as: what is the proper standard for assessing whether an individual is substantially limited in performing manual tasks for a showing of disability under the ADA and did the Court of Appeals of the Sixth Circuit apply it?
Facts of the Case
Williams worked at Toyota’s automobile manufacturing plant in Georgetown, Kentucky. She worked with pneumatic tools to assemble engines and use of these tools caused pain in her hands, wrists, and arms. She was placed on permanent work restrictions that limited the tasks should perform. Although her work was limited to allowable tasks, she still missed work and filed a claim under the Kentucky Worker’s Compensation Act. This claim was settled and she returned to work. She continued to be unsatisfied with Toyota’s efforts to accommodate her work restrictions, so she sued in District Court alleging ADA violations. This suit was settled and Williams again returned to work.
Upon this second return she was placed in a team that performed four tasks (1) assembly paint, (2) paint second inspection, (3) shell body audit, and (4) ED surface repair. For a couple of years she performed only the first two tasks. “Assembly paint” requires visually inspecting painted cars for flaws. Initially this required manual steps of opening doors, trunk, or hood, but later this job became simply visual inspections. “Paint second inspection” involves using hands to wipe each painted car with a glove. The parties agree that Williams could perform these two tasks and her performance was satisfactory.
Later, Toyota decided to rotate workers through all four of the team tasks. After training, she added “shell body audit” to her tasks. This required applying highlight oil to the hood, fender, doors, rear quarter panel, and trunk of the car. The oil is applied with a sponge attached to a block of wood. Wiping the cars requires holding hands and arms up around shoulder height for several hours at a time. Shortly after starting this new task, Williams developed pain in her neck and shoulders. The in-house doctor saw her and a number of inflammation issues were diagnosed. Williams requested to be returned to performing only the first two tasks, which she claimed could do without difficulty.
At this point the parties disagree factually. Williams states that Toyota refused this request and forced her to continue the shell body audit task, which caused further injury. Toyota states that Williams began missing work on a regular basis. Regardless, in December 1996, Williams’ physicians put her on no-work-of-any-kind restriction. In January 1997, she was terminated by Toyota, citing Williams’ poor attendance record.
Williams filed a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC). She received a right to sue letter and filed against Toyota in the District Court for the Eastern District of Kentucky. Among the claims was that Toyota had violated the ADA. She based her claim of disability on her physical impairments that allegedly substantially limited her in several ways, including performing manual tasks (535 US 184, 187-90).
Statement of Rule
For a plaintiff to demonstrate a “substantial limitation in performing manual tasks” as a basis for a finding of disability under the ADA, “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” (535 U.S. 184, 198).
Policy
This standard must be interpreted strictly as Congress did not intend for everyone that had a physical impairment that prevented some isolated, unimportant, or particularly difficult manual task to qualify as disabled. A strict interpretation is also supported by the relatively restricted number of “43 million people in Americans with one or more physical or mental disabilities” recited within the ADA statute in 1990 when enacted (535 U.S. 184, 197).
Reasoning
The Court begins by quoting the relevant definition for disability within the ADA at issue: a “disability” is “(A) a physical or mental impairment that substantially limits one of more of the major life activities of such individual . . . “ (42 U.S.C. § 12112(b)(5)(A) (1994)).
A discussion of possible sources for interpretation follows this definition. The first source is the regulations that interpret the Rehabilitation Act of 1973. That is because when Congress drafted the ADA’s definition of disability, they used an almost word for word copy of the definition of “handicapped individual” from the Rehabilitation Act and such repetition is means that prior interpretations of the identical term are included in Congress’ intent. Additionally, Congress stated explicitly that nothing in the ADA should apply a lesser standard than those in the Rehabilitation Act, strongly suggesting it authorized using the Rehabilitation Act to interpret the ADA.
A second possible source of interpretation is the regulations promulgated by the EEOC. Although no agency has been given authority to interpret the term “disability” in the ADA, the EEOC has. As neither party has argued that the EEOC regulation is unreasonable, the Court determines it is proper to rely upon those regulations in this case.
When turning to ADA definition at issue, the Court notes that the initial proof is whether the claimant has a physical or mental impairment. It then discusses the definition of impairment as provided by the regulations interpreting the Rehabilitation Act. In particular, physical impairment is defined as
any physiological disorder or condition, cosmetic disfigurement,
or anatomical loss affecting one or more of the following body systems: neurological, musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive, digestive, genito-urinary; hemic and lymphatic; skin and endocrine. 45 CFR § 84.3(j)(2)(i) (2001).
But just having mere impairment is not enough to be disabled. The Court observes that the impairment must be of the severe enough to limit a major life activity. The Court notes that the regulations interpreting the Rehabilitation Act states that “performing manual tasks” is considered a major life activity.
Finally, the limitation on the major life activity must be substantial. The Court observes that the Rehabilitation Act does not define “substantial limitation.” Instead, the EEOC has created its own definition for use within the ADA. Specifically, it means
[u]nable to perform a major life activity that the average person in the
general population can perform or significantly restricted as to the
condition, manner, or duration under which an individual can perform
major life activity as compared to the condition, manner, or duration
under which the average person in the general population can perform
the same major life activity. 29 CFR § 1630.2(j) (2001).
The regulations even provide what factors should be considered in determining whether an individual is substantially limited in a major life activities. These factors include:
the nature and severity of the impairment; the duration or expected
duration of the impairment, the permanent or long-term impact, or
the expected permanent or long-term impact of or resulting from the
impairment. 29 CFR §§ 1630.2(j)(2)(i)-(iii).
Thus, the final analytical framework for this case resolves into determining “what must a plaintiff demonstrate to establish a substantial limitation in the specific major life activity of performing manual tasks” (535 U.S. 184, 196).
The Court applies this framework by first using the dictionary to define the terms “substantially” (considerable or large degree) and notes that “substantially limits” must exclude impairments that interfere only in a minor way from the performance of manual tasks. Next, it addresses the term “major” (greater in dignity, rank, importance, or interest) and states that in order for manual tasks to fall within the category of major life activities they must be central to daily life (535 U.S. 184, 197).
The Court then sets forth the policy reasons for having a strict standard, which is summarized above, followed by the rule stated above.
The Court states that merely having a diagnosis is not sufficient for a finding of disability. Instead, a case-by-case assessment of each individual is necessary under the Act and particularly for this case, given the wide range of symptoms exhibited with by those diagnosed with carpel tunnel syndrome, one of the impairments suffered by Williams. The Court summarizes the wide range of symptoms carpel tunnel can include and the fact that some carpel tunnel self-resolves. Thus, mere diagnosis with this syndrome is found not enough to determine Williams is disabled within the meaning of the ADA.
The Court then sets forth the standards used by the Court of Appeals of the Sixth Circuit in its decision. In particular, the Court states that it used the standard that the “plaintiff must show that her manual disability involves a ‘class’ of manual activities” and that those activities must “affect[t] the ability to perform tasks at work.” Justice O’Connor rejects both of these ideas as incorrect (535 U.S. 184, 201).
The first aspect of the standard is rejected because the Supreme Court had only applied the idea that a “class” of activities must be shown if the substantial limitation was to the major life activity of “working” (Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999)). This standard was put in place in order to avoid focus on an individual job for the “working” major life category, but not to imply that impairment over a class of activities was necessary for each and every major life activity category. This Court therefore declined to extend the Sutton “class” rule beyond the specific major life activity of “working.”
Furthermore, as to the second aspect of this standard, the Court states that the lower court erred by focusing on manual tasks associated only with the job. Instead, the correct analysis is examining the ability to perform the variety of tasks central to daily life. It also stated there was no support in the ADA, previous Supreme Court decisions, or the regulations for analyzing impairment only in the workplace. This approach is also discredited by the fact that the definition of the term “disability” applies to all parts of the ADA, only part of which is related to employment, while other ADA parts deal with public transportation and privately provided accommodations so a focus on the workplace is incorrect.
An even more important point, however, was that manual tasks done for particular jobs are not necessarily major life activities for other people. For the manual task at issue – holding hands and arms at shoulder levels or above for extended periods of time – is not an important part of most people’s daily lives, thus the Court of Appeals erred in focusing on Williams’ inability to perform her specialized assembly line job to support a finding that she was substantially limited in performing manual tasks.
Instead, the Court of Appeals should have focused on the information they specifically disregarded, namely personal hygiene, personal or household chores. The Court states that it is precisely these types of tasks that should central to the analysis to determine if Williams was substantially limited in performing manual tasks and thus “disabled” under the ADA. In particular, the record available to the Supreme Court stated that even after her condition worsened Williams could still “brush her teeth, wash her face, bathe, tend her flower garden, fix breakfast, do laundry and pick up around the house” (Appendix to Petition for Certiorari, A 32-34). What she had to avoid was “sweeping, dancing, some dressing tasks, playing with her children to the extent she used to, some gardening tasks, and driving long distances” (Appendix to Petition for Certiorari, A 32, 38-39). In the Court’s view, these statements are the primary source of evidence as to whether Williams did or did not meet the definition of “disabled” under the ADA.
Holding
Based on the facts before it, the Supreme Court held that the documented changes in Williams’ life because of her physical impairments did not amount to enough impact to establish a substantial limitation in her ability to perform manual tasks that were of central importance in her life. Therefore, it reversed the Court of Appeals decision that found her “disabled” under the ADA and the partial summary judgment to that effect (535 U.S. 184, 203).
References
American Disabilities Act, 42 U.S.C. § 12112(b)(5)(A) (1994).
Sutton v. United Air Lines, Inc., 527 U.S. 471 (1999).
Toyota Motor Mfg. Ky. v. Williams, 154 U.S. 184 (2002).
Toyota Motor Mfg. Ky. v. Williams, 224 F.3d 840 (6th Cir. 2000).