Toyota Motor Mfg., Ky, Inc. v. Williams, Ella (01/08/2002)

Questions presented: Did the 6th circuit correctly hold, though in conflict with other circuits, that an impairment to perform a number of tasks associated with specific job qualities is a "disability" under the Americans with Disabilities Act?

BY JOHN HALLORAN, MEDILL NEWS SERVICE

Using vibrating pneumatic tools while working on an assembly line in 1993, Ella Williams developed carpal tunnel syndrome in both wrists, and back and neck pain after just three months on the job. She continued working in severe pain and was moved to a less physically demanding job.

But when her job responsibilities were expanded and her pain recurred, Toyota refused to return her to her previous tasks. Williams filed suit, under the Americans with Disabilities Act, in 1997, saying that Toyota failed to accommodate her disability.

The Americans with Disabilities Act of 1990 requires employers to make "reasonable accommodations" for qualified workers who are limited by mental or physical impairments. The act covers disabilities that "substantially limit one or more major life activities" such as walking, seeing, working or performing manual tasks.

The ADA, however, is separate from workers compensation or Social Security, which provide benefits for those who are disabled and unable to work.

After her first occurrence of pain in 1993, Williams filed an ADA claim, saying that Toyota would not accommodate her disability. Williams settled the claim after a Toyota doctor reviewed her and said that she needed to be assigned to light duty only. So the company moved her to a job as a paint inspector - still on the assembly line - with doctors instructions to restrict her movements. Toyota limited her job description to only three of the five tasks that paint inspectors are normally responsible for.

By all accounts, she performed her new job well and without pain for three years, until the company expanded her job requirements to include wiping down the passing cars with a tool that required her to hold her arms above chest level. Williams was unable to properly raise her arms or grip the tool, a wooden block attached to a sponge. The additional tasks brought back her pain, so she asked Toyota to relieve her of them.

Toyota would not let her resume her previous job, so in late 1996 she stopped coming to work and was fired on Jan. 27, 1997.

Williams contends she is disabled because her ability to perform manual tasks is limited - one legal definition of disability - and she sued in U.S. District Court in Lexington, Ky., saying Toyota failed to accommodate her disability. Toyota contended that because Williams can do other work and many everyday activities, she is only partially impaired and does not qualify for protection under the ADA.

The District Court ruled for Williams in 1999 and Toyota appealed to the 6th Circuit Court of Appeals. The 6th Circuit ruled 2-1 for Williams, agreeing she was substantially disabled because her impairments made it difficult to perform a range of tasks. The appeals court also agreed that working is a major life activity covered under the ADA.

"The fact that Williams can perform a range of isolated, non-repetitive manual tasks performed over a short period of time, such as tending to her personal hygiene or carrying out personal or household chores, does not effect a determination that her impairment substantially limits her ability to perform the range of manual tasks associated with an assembly line job," Judge Gilbert Merritt wrote for the majority.

But, the ruling was not a complete victory for Williams.

"Although we have concluded that Williams is disabled and that there is a triable issue of fact as to whether the defendant auto manufacturer failed to reasonably accommodate her disability," Merritt wrote, "the defendant is still free to raise any viable defenses as to why it was unable to accommodate Williams, such as undue hardship and business necessity."

In dissent, Judge Danny Boggs wrote that Toyota had already accommodated Williams by assigning her to lighter work in a paint inspection unit.

"Specifically, she was assigned two of the four jobs usually given to such a worker --inspecting the assembly and paint jobs and, as the court correctly notes, Ômanually wiping down each newly painted car. Toyota later asked her to perform a third job (though still not all four) of those jobs usually assigned to someone in her position," he wrote. "This task caused Williams considerably more physical difficulty. Of course not every amount of physical difficulty with any one task will be considered a disability...this inability to perform certain types of tasks would not likely constitute being disabled with regard to the major life activity of working."

On April 16, 2001, the U.S. Supreme Court granted certiorari in the case, and allowed the National Association of Manufacturers to file an amicus brief.

Since its inception, the ADA has spurred several Supreme Court cases, the first group of which were ruled on two years ago, that have tested its depth and breadth. In Sutton v. United Air Lines, the court found that uncorrected conditions, such as poor eyesight, do not amount to disabilities.

A similar case before the Court this term is US Airways v Barnett, in which a baggage handler developed job-related back problems and was refused a request to be transferred to the mailroom.

On Jan. 8, 2002, a unanimous Court held that Williams was not entitled under the ADA to special treatment on the job.

In noting that disability under the act can't be assessed by looking only at a person's fitness to work, Justice Sandra Day O' Connor wrote for the Court that "the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job."