Legal Bulletin

November 9, 2001

The Supreme Court Hears Toyota v. Williams:
Implications for workers requesting reasonable accommodations

The U.S. Supreme Court this week heard oral arguments in the Toyota v. Williams, a case that centers on a core question: how functionally limited does a person need to be in order be "disabled" and therefore receive the protections of the ADA.

The plaintiff in this case is Ella Williams, who worked for Toyota in its Kentucky assembly plant. Ms. William's work on the assembly line using pneumatic tools caused her to develop carpal tunnel syndrome and tendonitis in her wrists, arms and neck. In 1993, as part of a settlement that provided her with a reasonable accommodation, Ms. Williams started working on the quality control inspection team, which had four different inspection workstations for inspecting different parts of the vehicle for imperfections. Ms. Williams rotated through two of those workstations, which had her opening and closing parts of the car and visually inspecting the car, with very little repetition in movement. In 1996, her job duties were expanded to include another inspection workstation where she would wipe down the passing cars with a sponge soaked in oil. This new workstation required Ms. Williams to keep her hands and arms at shoulder height or above with repetitive movements of her arms and hands. Her impairments flared up and resulted in permanent work restrictions. She could have performed satisfactorily at the two workstations where she originally worked, but not the other workstations, which for her was more physically demanding. Eventually, her employment was terminated because she could not perform at the third workstation. Ms. Williams sued Toyota, claiming that Toyota's refusal to reasonably accommodate her, by allowing her to go back to working at the two less strenuous workstations, was a violation of the Americans with Disabilities Act (ADA).

In order to be eligible to sue under the ADA, an individual must be a "qualified individual with a disability," i.e. a person with a disability who can perform the essential functions of the position, with or without a reasonable accommodation. The definition of disability that Ms. Williams had to meet in order to be eligible for any reasonable accommodation, or to sue at all under the ADA is

Before trial, the lower court in this case ruled as a matter of law that Ms. Williams did not have a "disability," as defined by the ADA, because she was not substantially limited in major life activities. Major life activities may include, among others, taking care of oneself, performing manual tasks and, in limited circumstances, working in a broad range or class of jobs. The appellate court reversed the lower court's ruling, holding that Ms. Williams could be found by a jury to be substantially limited in the major life activity of "performing manual tasks," because she could not perform a broad range of manual activities that require the gripping of tools and keeping of arms at shoulder height or above repetitively for an extended period of time. This affected several areas of her life, including work, recreation, household maintenance and living generally, said the court. Toyota appealed the decision to the Supreme Court, arguing that to receive the protection of the ADA, Ms. Williams needed to be considerably limited in using her hands to perform "a broad range of basic functions needed to meet the essential demands of everyday life." The appellate court's opinion can be found at http://laws.findlaw.com/6th/00a0223p.html.

The question of who is and who is not "disabled" enough to receive the protections under the ADA is a vexing problem for people with disabilities. Many courts have consistently used this definition of disability to exclude people who self-identify as having a disability and who have impairments that truly limit what they can and cannot do in work and life. Without an employee overcoming this initial hurdle, a court will not even consider

Although the ADA does allow someone to sue if their employer regards them as having a disability, or if the employee has a past record of disability, these eligible categories of people must also show that the "disability" in those two categories are "substantially limiting."

For those employees who can benefit from assistive technology, and become more productive workers as a result, they need to assess whether it is worth the risk of asking for AT or another reasonable accommodation, when the employer and its lawyers might not consider them disabled enough. An employer might not only deny the AT, but also act against the employee in other ways. In addition, if the Supreme Court rules in favor of Toyota in this case, employers might misread the ruling as not merely applying to Ms. Williams, but also to the tens of thousands of people with carpal tunnel syndrome and similar disabilities, effectively denying them equal employment rights no matter how limited they are.