Date: 01-08-2002

Case Style: Toyota Manufacturing, Kentucky, Inc. v. Williams

Case Number: 00—1089

Judge: O'Connor

Court: United States Supreme Court

Plaintiff's Attorney: Unknown

Defendant's Attorney: Unknown

Description: Claiming to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, respondent sued petitioner, her former employer, for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA), 42 U. S. C. §12112(b)(5)(A). The District Court granted petitioner summary judgment, holding that respondent™s impairment did not qualify as a isdisabilitylA under the ADA because it had not iosubstantially limit[ed]li any inmajor life activit[y],lr §12102(2)(A), and that there was no evidence that respondent had had a record of a substantially limiting impairment or that petitioner had regarded her as having such an impairment. The Sixth Circuit reversed, finding that the impairments substantially limited respondent in the major life activity of performing manual tasks. In order to demonstrate that she was so limited, said the court, respondent had to show that her manual disability involved a inclasslt of manual activities affecting the ability to perform tasks at work. Respondent satisfied this test, according to the court, because her ailments prevented her from doing the tasks associated with certain types of manual jobs that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time. In reaching this conclusion, the court found that evidence that respondent could tend to her personal hygiene and carry out personal or household chores did not affect a determination that her impairments substantially limited her ability to perform the range of manual tasks associated with an assembly line job. The court granted respondent partial summary judgment on the issue whether she was disabled under the ADA.

Under the Americans with Disabilities Act of 1990 (ADA or Act), 104 Stat. 328, 42 U. S. C. §12101 et seq. (1994 ed. and Supp. V), a physical impairment that i侪substantially limits one or more . . . major life activitiesls is a i侪disability.le 42 U. S. C. §12102(2)(A) (1994 ed.). Respondent, claiming to be disabled because of her carpal tunnel syndrome and other related impairments, sued petitioner, her former employer, for failing to provide her with a reasonable accommodation as required by the ADA. See §12112(b) (5)(A). The District Court granted summary judgment to petitioner, finding that respondent™s impairments did not substantially limit any of her major life activities. The Court of Appeals for the Sixth Circuit reversed, finding that the impairments substantially limited respondent in the major life activity of performing manual tasks, and therefore granting partial summary judgment to respon- dent on the issue of whether she was disabled under the ADA. We conclude that the Court of Appeals did not apply the proper standard in making this determination because it analyzed only a limited class of manual tasks and failed to ask whether respondent™s impairments prevented or restricted her from performing tasks that are of central importance to most people™s daily lives.

I

Respondent began working at petitioner™s automobile manufacturing plant in Georgetown, Kentucky, in August 1990. She was soon placed on an engine fabrication assembly line, where her duties included work with pneumatic tools. Use of these tools eventually caused pain in respondent™s hands, wrists, and arms. She sought treatment at petitioner™s in-house medical service, where she was diagnosed with bilateral carpal tunnel syndrome and bilateral tendinitis. Respondent consulted a personal physician who placed her on permanent work restrictions that precluded her from lifting more than 20 pounds or from irfrequently lifting or carrying of objects weighing up to 10 pounds,ln engaging in inconstant repetitive . . . flexion or extension of [her] wrists or elbows,ln performing i侤over- head work,l™ or using isvibratory or pneumatic tools.li Brief for Respondent 2; App. 45Œ46.

In light of these restrictions, for the next two years petitioner assigned respondent to various modified duty jobs. Nonetheless, respondent missed some work for medical leave, and eventually filed a claim under the Kentucky Workers™ Compensation Act. Ky. Rev. Stat. Ann. §342.0011 et seq. (1997 and Supp. 2000). The parties settled this claim, and respondent returned to work. She was unsatisfied by petitioner™s efforts to accommodate her work restrictions, however, and responded by bringing an action in the United States District Court for the Eastern District of Kentucky alleging that petitioner had violated the ADA by refusing to accommodate her disability. That suit was also settled, and as part of the settlement, respondent returned to work in December 1993.

Upon her return, petitioner placed respondent on a team in Quality Control Inspection Operations (QCIO). QCIO is responsible for four tasks: (1) i1assembly paintlm; (2) i侬paint second inspection responsible for four tasks: (1) i1assembly paintlm; (2) i侬paint second inspectionl

During the fall of 1996, petitioner announced that it wanted QCIO employees to be able to rotate through all four of the QCIO processes. Respondent therefore re- ceived training for the shell body audit job, in which team members apply a highlight oil to the hood, fender, doors, rear quarter panel, and trunk of passing cars at a rate of approximately one car per minute. The highlight oil has the viscosity of salad oil, and employees spread it on cars with a sponge attached to a block of wood. After they wipe each car with the oil, the employees visually inspect it for flaws. Wiping the cars required respondent to hold her hands and arms up around shoulder height for several hours at a time.

A short while after the shell body audit job was added to respondent™s rotations, she began to experience pain in her neck and shoulders. Respondent again sought care at petitioner™s in-house medical service, where she was diag- nosed with myotendinitis bilateral periscapular, an in- flammation of the muscles and tendons around both of her shoulder blades; myotendinitis and myositis bilateral forearms with nerve compression causing median nerve irritation; and thoracic outlet compression, a condition that causes pain in the nerves that lead to the upper extremities. Respondent requested that petitioner ac- commodate her medical conditions by allowing her to return to doing only her original two jobs in QCIO, which respondent claimed she could still perform without difficulty.

The parties disagree about what happened next. Ac- cording to respondent, petitioner refused her request and forced her to continue working in the shell body audit job, which caused her even greater physical injury. According to petitioner, respondent simply began missing work on a regular basis. Regardless, it is clear that on December 6, 1996, the last day respondent worked at petitioner™s plant, she was placed under a no-work-of-any-kind restriction by her treating physicians. On January 27, 1997, respondent received a letter from petitioner that terminated her employment, citing her poor attendance record.

Respondent filed a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC). After receiving a right to sue letter, respondent filed suit against petitioner in the United States District Court for the Eastern District of Kentucky. Her complaint alleged that petitioner had violated the ADA and the Kentucky Civil Rights Act, Ky. Rev. Stat. Ann. §344.010 et seq. (1997 and Supp. 2000), by failing to reasonably accommodate her disability and by terminating her employment. Respondent later amended her complaint to also allege a violation of of the Family and Medical Leave Act of 1993 (FMLA), 107 Stat. 6, as amended, 29 U. S. C. §2601 et seq. (1994 ed. and Supp. V).

Respondent based her claim that she was i侬disabledln under the ADA on the ground that her physical impairments substantially limited her in (1) manual tasks; (2) housework; (3) gardening; (4) playing with her children; (5) lifting; and (6) working, all of which, she argued, constituted major life activities under the Act. Respondent also argued, in the alternative, that she was disabled under the ADA because she had a record of a substantially limiting impairment and because she was regarded as having such an impairment. See 42 U. S. C. §§12102(2)(BŒC) (1994 ed.).

After petitioner filed a motion for summary judgment and respondent filed a motion for partial summary judgment on her disability claims, the District Court granted summary judgment to petitioner. Civ. A. No. 97Œ135 (Jan. 26, 1999), App. to Pet. for Cert. AŒ23. The court found that respondent had not been disabled, as defined by the ADA, at the time of petitioner™s alleged refusal to accommodate her, and that she had therefore not been covered by the Act™s protections or by the Kentucky Civil Rights Act, which is construed consistently with the ADA. Id., at AŒ29, AŒ34 to AŒ47. The District Court held that respondent had suffered from a physical impairment, but that the impairment did not qualify as a disability because it had not iosubstantially limit[ed]li any inmajor life activit[y],lr 42 U. S. C. §12102(2)(A). App. to Pet. for Cert. AŒ34 to AŒ 42. The court rejected respondent™s arguments that gardening, doing housework, and playing with children are major life activities. Id., at AŒ35 to AŒ36. Although the court agreed that performing manual tasks, lifting, and working are major life activities, it found the evidence insufficient to demonstrate that respondent had been substantially limited in lifting or working. Id., at AŒ36 to AŒ42. The court found respondent™s claim that she was substantially limited in performing manual tasks to be i€irretrievably contradicted by [respondent™s] continual insistence that she could perform the tasks in assembly [paint] and paint [second] inspection without difficulty.lt Id., at AŒ36. The court also found no evidence that respondent had had a record of a substantially limiting impairment, id., at AŒ43, or that petitioner had regarded her as having such an impairment, id., at AŒ46 to AŒ47.

The District Court also rejected respondent™s claim that her termination violated the ADA and the Kentucky Civil Rights Act. The court found that even if it assumed that respondent was disabled at the time of her termination, she was not a ioqualified individual with a disability,lሀ 42 U. S. C. §12111(8) (1994 ed.), because, at that time, her physicians had restricted her from performing work of any kind, App. to Pet. for Cert. AŒ47 to AŒ50. Finally, the court found that respondent™s FMLA claim failed, because she had not presented evidence that she had suffered any damages available under the FMLA. Id., at AŒ50 to AŒ54.

Respondent appealed all but the gardening, housework, and playing-with-children rulings. The Court of Appeals for the Sixth Circuit reversed the District Court™s ruling on whether respondent was disabled at the time she sought an accommodation, but affirmed the District Court™s rulings on respondent™s FMLA and wrongful termination claims. 224 F. 3d 840 (2000). The Court of Appeals held that in order for respondent to demonstrate that she was disabled due to a substantial limitation in the ability to perform manual tasks at the time of her accommodation request, she had to ioshow that her manual disability involve[d] a ‚class™ of manual activities affecting the ability to perform tasks at work.lm Id., at 843. Respondent satisfied this test, according to the Court of Appeals, because her ailments iiprevent[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.ls Ibid. In reaching this conclu- sion, the court disregarded evidence that respondent could ieten[d] to her personal hygiene [and] carr[y] out personal or household chores,ld finding that such evidence ivdoes not affect a determination that her impairment substantially limit[ed] her ability to perform the range of manual tasks associated with an assembly line job,lb ibid. Because the Court of Appeals concluded that respondent had been substantially limited in performing manual tasks and, for that reason, was entitled to partial summary judgment on the issue of whether she was disabled under the Act, it found that it did not need to determine whether respon- dent had been substantially limited in the major life ac- tivities of lifting or working, ibid., or whether she had had a i

We granted certiorari, 532 U. S. 970 (2001), to consider the proper standard for assessing whether an individual is substantially limited in performing manual tasks. We now reverse the Court of Appeals™ decision to grant partial summary judgment to respondent on the issue whether she was substantially limited in performing manual tasks at the time she sought an accommodation. We express no opinion on the working, lifting, or other arguments for disability status that were preserved below but which were not ruled upon by the Court of Appeals.

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Click the case caption above for the full text of the Court's opinion.

Outcome: The Sixth Circuit did not apply the proper standard in determining that respondent was disabled under the ADA because it analyzed only a limited class of manual tasks and failed to ask whether respondent’s impairments prevented or restricted her from performing tasks that are of central importance to most people’s daily lives. Pp. 7—18.

(a) The Court’s consideration of what an individual must prove to demonstrate a substantial limitation in the major life activity of performing manual tasks is guided by the ADA’s disability definition. “Substantially” in the phrase “substantially limits” suggests “considerable” or “to a large degree,” and thus clearly precludes impairments that interfere in only a minor way with performing manual tasks. Cf. Albertson’s, Inc. v. Kirkingburg, 527 U.S. 555, 565. Moreover, because “major” means important, “major life activities” refers to those activities that are of central importance to daily life. In order for performing manual tasks to fit into this category, the tasks in question must be central to daily life. To be substantially limited in the specific major life activity of performing manual tasks, therefore, 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. The impairment’s impact must also be permanent or long-term. See 29 CFR §§1630.2(j)(2)(ii—iii).

It is insufficient for individuals attempting to prove disability status under this test to merely submit evidence of a medical diagnosis of an impairment. Instead, the ADA requires them to offer evidence that the extent of the limitation caused by their impairment in terms of their own experience is substantial. Id., at 567. That the Act defines “disability” “with respect to an individual,” §12102(2), makes clear that Congress intended the existence of a disability to be determined in such a case-by-case manner. See, e.g., Sutton v. United Air Lines, Inc., 527 U.S. 471, 483. An individualized assessment of the effect of an impairment is particularly necessary when the impairment is one such as carpal tunnel syndrome, in which symptoms vary widely from person to person. Pp. 11—14.

(b) The Sixth Circuit erred in suggesting that, in order to prove a substantial limitation in the major life activity of performing manual tasks, a plaintiff must show that her manual disability involves a “class” of manual activities, and that those activities affect the ability to perform tasks at work. Nothing in the ADA’s text, this Court’s opinions, or the regulations suggests that a class-based framework should apply outside the context of the major life activity of working. While the Sixth Circuit addressed the different major life activity of performing manual tasks, its analysis erroneously circumvented Sutton, supra, at 491, by focusing on respondent’s inability to perform manual tasks associated only with her job. Rather, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people’s daily lives. Also without support is the Sixth Circuit’s assertion that the question whether an impairment constitutes a disability is to be answered only by analyzing the impairment’s effect in the workplace. That the Act’s “disability” definition applies not only to the portion of the ADA dealing with employment, but also to the other provisions dealing with public transportation and public accommodations, demonstrates that the definition is intended to cover individuals with disabling impairments regardless of whether they have any connection to a workplace. Moreover, because the manual tasks unique to any particular job are not necessarily important parts of most people’s lives, occupation-specific tasks may have only limited relevance to the manual task inquiry. In this case, repetitive work with hands and arms extended at or above shoulder levels for extended periods, the manual task on which the Sixth Circuit relied, is not an important part of most people’s daily lives. Household chores, bathing, and brushing one’s teeth, in contrast, are among the types of manual tasks of central importance to people’s daily lives, so the Sixth Circuit should not have disregarded respondent’s ability to do these activities. Pp. 14—17.

224 F.3d 840, reversed and remanded.

Plaintiff's Experts: Unknown

Defendant's Experts: Unknown

Comments: E-mail suggested corrections, comments and/or corrections to: Kent Morlan

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