Toyota Motor Manufacturing Kentucky Inc. v. Williams

Toyota Motor Manufacturing Kentucky Inc. v. Williams

The Americans with Disabilities Act protects people who have become disabled from losing their job, as long as reasonable accommodations—like light duty assignments or ergonomic equipment—could allow them to do their job again. Toyota Motor Manufacturing Kentucky Inc. v. Williams was a 2002 Supreme Court case that ruled on whether a woman's carpal tunnel syndrome, which prevented her from doing her duties at an auto manufacturing plant, could be construed as a disability under the Americans with Disabilities Act.

Williams' Carpal Tunnel Syndrome

The plaintiff in the case worked on an assembly line for Toyota, and in the course of her job duties began to develop carpal tunnel syndrome, a repetitive stress injury of the wrists that leads to numbness in the fingers and hands. When Toyota found out, they initially moved her into a different duty station, which allowed her to do her work with no impairment.

However, her job duties soon began to change, and eventually required her to do another activity that exacerbated her carpal tunnel. She asked to go back to working only on the job duties that did not cause her pain or impair her work, but her employer refused, resulting in a lawsuit under the Americans with Disabilities Act.

District and Appellate Court Holdings

Williams encountered her first setback when the district court dismissed her case. However, on appeal, the Sixth Circuit Court found that Williams qualified under the Americans with Disabilities Act because her carpal tunnel syndrome made it impossible for her to perform work-related manual tasks. Toyota maintained that because Williams was able to do other activities with her hands—like brushing her hair, washing her hands, or sweeping her kitchen—that she did not really qualify as disabled and merely lacked an ability to do a particular specialized task. Toyota appealed the case to the Supreme Court, where it became Toyota Motor Manufacturing Kentucky Inc. v. Williams.

Supreme Court Decision

The 2002 ruling in Toyota Motor Manufacturing Kentucky Inc. v. Williams was that the appeals court had been incorrect in declaring Williams disabled. The Supreme Court ruled unanimously, in an opinion written by Justice Sandra Day O'Connor, that there was no proof that Williams was limited in performing manual tasks in general—only the specific manual tasks required of her by her specialized assembly line job.

In order to qualify as disabled, the Court said, ADA plaintiffs must be affected by their disability not only in the course of their job duties but also in activities “of central importance to people's daily lives.” However, the Supreme Court did not go as far as to declare that Williams was not in fact disabled. Instead, they simply noted that this had not been proven and that the Sixth Circuit had not applied the correct definition of a disability. The case was remanded to the Sixth Circuit for additional review.

This decision in Toyota Motor Manufacturing Kentucky Inc. v. Williams was perceived as significantly limiting plaintiffs' ability to sue under the Americans with Disabilities Act, especially for injuries that were the result of repetitive physical stresses at work and only impacted their abilities to perform their job.