Toyota Motor Manufacturing, Kentucky v. Williams; Case Brief for Law School
The Problem Presented by the Case
The case presented the following problems (Anfang, 2003): I] What constitutes a major life activity? II] Can work-related activities be regarded as major life activities? What is working life and what is the extent of importance in an individual’s life? III] What does the term “substantial impairment” lend itself to? What is the functional impact of a medically certified impairment, whether physical or mental? IV] Is it merely sufficient to demonstrate the medical diagnosis of impairment so as to be classified as “disabled” or suffering “impairment”? and lastly V] What was Congress intention in enacting the ADA?
Background
The Toyota Motor Manufacturing, Kentucky v. Williams case argued before and decided by the Supreme Court in 2002 pitted a Toyota Motor Company (hereafter “Toyota”) against one of its female employees. Ella Williams, who had begun working at Toyota’s Kentucky plant in 1990 at the firm’s assembly line, but was soon thereafter diagnosed with bilateral carpal tunnel syndrome (CTS) and bilateral tendinitis (Anfang, 2003).
Consequently, due to her physician’s restrictions to avoid repetitive wrist or elbow-related movements, lifting of heavy weights, and use of vibrating pneumatic machinery or tools, Toyota modified her job description and, by late 1993, Williams had successfully filed her very first American Disabilities Act (ADA) claim, which Toyota settled, and begun work as a visual inspector for painted cars (Anfang, 2003).
Although she could perform this initial task without significant or disabling impairment, Williams was diagnosed with myositis and thoracic outlet compression in 1996 after her employer had added two strenuous tasks to her quality control task. This diagnosis was the cause of her neck and shoulder pains. At this point, her physician restricted her entirely from work and, in 1997 (Anfang, 2003), Toyota terminated her employment contract due to regular non-attendance.
In turn, Williams filed in the district court for protection under the Family and Medical Leave Act (1993), American Disabilities Act (1990), and the Kentucky Civil Rights Act. The court ruled in Toyota’s favor and she appealed to the Sixth Circuit Court of Appeals, which quashed the lower court’s summary judgment. Certiorari proceedings by the Supreme Court unanimously overruled the appeals court decision, finding that the respondent did experience substantial impairment due to her medical conditions and therefore could not be classified as disabled (Anfang, 2003). The Court remanded the case back to the district court, which had a similar ruling, for further judicial action.
The Ruling
The clash between the lower court and the Supreme Court on the definition of “major life activities” and “substantial impairment” had been raging since the 1990 passage of the ADA. While the 6th Circuit Appeals Court had delivered partial judgment in favor of the respondent, the Supreme Court had previously narrowed the definition of these two pertinent terms especially in the Sutton v. United Airlines 1999 case (Anfang, 2003). The Supreme Court held that the appeals court had applied the wrong standard in determining whether Williams, despite her medically substantiated physical impairments, suffered any impairment in performing “major life (manual) activities”. The ruling further clarified that working, unless where it has been evidentially demonstrated to be to the contrary, was not a major life activity in itself.
Impact
The ruling was hailed as a significant victory for employers. In effect, the Court restricted ADA coverage by narrowing the definition of disability. Arguments have been made that this restriction robs victims of discrimination of legal protection (Anfang, 2003). Although ruling that development of an occupation-related impairment does not automatically invoke ADA protection, the Court conceded that once the stringent definition of substantial impairment had been met, a worker could not be denied appropriate remedy (Anfang, 2003).
