Individual with Carpal Tunnel Syndrome Did Not Have a Disability Under the ADA

By Melanie R. Margolis

In Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002), accessible at   http://supct.law.cornell.edu/supct/html/00-1089.ZS.html, Ella Williams sued her former employer under the Americans with Disabilities Act (ADA) claiming to be unable to perform her automobile assembly line job because she suffered from carpal tunnel syndrome. The question presented is whether the court below properly determined that Williams was disabled as defined under the ADA.

In August 1990, Williams began working for Toyota Motor Manufacturing, Kentucky, Inc. (Toyota) in an automobile manufacturing plant. Her assembly line duties required the use of tools, which eventually caused pain in her hands, wrists, and arms. Toyota's in-house medical service diagnosed her with carpal tunnel syndrome. Her personal physician placed her on permanent work restrictions that precluded her from lifting more than 20 pounds, frequently lifting more than 10 pounds, or engaging in repetitive flexing or extending of her wrists or elbows.

Toyota placed Williams on a team in Quality Control Inspection Operations (QCIO). QCIO teams handled four tasks of which she was responsible for two. For two years, she rotated between visual inspection of painted cars and performing the "paint second inspection," which required team members to use their hands to wipe each painted car with a glove as it moved along a conveyor.

In 1996, Toyota required that all QCIO employees were to rotate through all four QCIO processes. The new requirement meant Williams would have to perform the shell body audit job, in which team members use a sponge attached to a block of wood to 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, then visually inspect for flaws. Williams had to hold her hands and arms up around shoulder height for several hours at a time to perform this task.

Soon after adding the shell body audit job to her rotation, Williams began to experience pain in her neck and shoulders. The in-house medical service diagnosed her with an inflammation of the muscles and tendons around both of her shoulder blades. Williams requested that Toyota accommodate her medical conditions by allowing her to return to doing only her original two jobs in QCIO, which she claimed she could still perform without difficulty. Her request was refused and, on December 6, 1996, she was placed under a no-work-of-any-kind restriction by her physician. On January 27, 1997, Williams was terminated by Toyota due to her poor attendance record.

Williams sued Toyota alleging, among other claims, that Toyota had violated the ADA by failing to reasonably accommodate her disability and by terminating her employment. Williams based her claim that she was “disabled” under the ADA on the ground that her physical impairments substantially limited her in a variety of manual tasks, including lifting and working, which, she argued, constituted major life activities under the ADA.

The ADA requires private employers to provide “reasonable accommodations" to known physical limitations of otherwise qualified individuals with disabilities unless the accommodations would impose undue hardship. 42 U.S.C. § 12112(b)(5)(A).  The term “disability” is defined in pertinent part as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual…." 42 U.S.C. § 12102(2).

The district court granted summary judgment to Toyota, finding that Williams had not been disabled, as defined by the ADA and that she had, therefore, not been covered by the ADA’s protections. The district court held that Williams had suffered from a physical impairment, but that it did not constitute a disability because it did not substantially limit any major life activity as required under the ADA.

The Court of Appeals for the Sixth Circuit reversed the district court, holding that in order for Williams to demonstrate that she was disabled due to a substantial limitation in her ability to perform manual tasks, she had to demonstrate that the major life activities limited by the disability were the same type of manual activities affecting her ability to perform her work. According to the appellate court, Williams met this test because her medical condition rendered her unable to perform many manual assembly line jobs. In reaching this conclusion, the court disregarded evidence that Williams could handle personal hygiene tasks and many household chores finding that her ability to do so was irrelevant to her limited ability to perform the range of tasks required by her assembly line job.

The Supreme Court granted certiorari to consider the proper standard for assessing whether an individual is substantially limited in performing manual tasks. The Supreme Court reversed the appellate court's decision on this issue. According to the Supreme Court, it was erroneous for the court below to have considered only Williams's ability to perform tasks associated specifically with her job. Instead, courts must consider the ability of the individual with the impairment to perform the variety of  manual tasks considered central to the daily lives of most people. The Supreme Court held that the appellate court did not apply the proper standard because it examined a limited class of manual tasks and did not examine whether Williams's impairments prevented her from performing tasks of central importance to most people’s daily lives.

In Texas, it is considered an unlawful employment practice for the state or other public employers or for private employers of 15 or more employees to discriminate in any manner against an individual with a disability. See Tex. Lab. Code § 21.051. Texas Labor Code § 21.002(6) defines a disability in relevant part as “a mental or physical impairment that substantially limits at least one major life activity” of an individual.  The Texas law is strikingly similar to the ADA, which, as noted above, defines a disability as “a physical or mental impairment that substantially limits one or more of the major life activities of such individual." In fact, one of the purposes of the Texas law is to "provide for the execution of the policies embodied in Title I of the Americans with Disabilities Act of 1990…." Tex. Lab. Code Sec. 21.001(3).

The current interpretation of the Texas and federal laws differs though. According to the U.S. Supreme Court, a court must consider the ability of the individual with the impairment to perform the variety of manual tasks considered central to the daily lives of most people. A single Texas appellate court case considered a similar restriction on lifting as it affected the ability to work. This case involved a truck driver who had a back injury that led to his physician's restricting him from lifting heavy objects. Primeaux v. Conoco, Inc., 961 S.W.2d 401 (Tex. App.--Houston [1st Dist.] 1997, no writ). The Texas court focused on whether his physical impairment substantially limited the major life activity of working and never looked at whether the truck driver could perform the manual tasks of everyday life. Instead, the court concentrated on his physical impairment and his limited education, which it said raised an issue of material fact as to whether his lifting restriction amounted to a substantial limitation on the major life activity of working. The Texas court also noted that it was important to look into whether the truck driver was significantly restricted in the ability to perform a class of jobs or a broad range of jobs in various classes when compared with the ability of the average person with comparable qualifications to perform those same jobs. This stands out in sharp contrast to the Supreme Court's statement in Toyota v. Williams that it was erroneous to have considered only Williams's ability to perform tasks associated specifically with her job. Texas courts may revisit this issue in light of Toyota v. Williams. In the alternative, the legislature may consider clarifying the Texas statute’s approach to the definition of a disability.

04/26/02