Americans with Disabilities Act

Supreme Court Refines the Definition of Disability under the ADA - Toyota Motor Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184 (2002)

This case builds on the previous United States Supreme Court cases defining what it means to be disabled under the ADA. (Bragdon v. Abbott, 524 U.S. 624, 118 S.Ct. 2196 (1998), Albertsons, Inc. v. Kirkingburg, 119 S.Ct. 2162 (1999), Sutton v. United Airlines, Inc., 119 S.Ct. 2139 (1999) and Murphy v. U.P.S., 119 S.Ct. 2133 (1999)). Plaintiff is an assembly line worker at Toyota Motor who developed carpel tunnel syndrome. She was unable to do her assembly line job and requested a light duty job as an accommodation. Toyota refused and she sued under the Americans with Disabilities Act. The district court found that she was not disabled under the Act because her carpel tunnel syndrome did not significantly affect the activities of daily life, only the specific tasks of her job. The Sixth Circuit reversed, finding that she was disabled and thus came under the coverage of the ADA. Toyota appealed and the United States Supreme Court accepted Cert. In its unanimous ruling, the court held that the ADA was not meant to cover every person who had problems functioning in a specific job, but only persons who were disabled such that their impairment significantly affected the activities of daily living. Since plaintiff could do the activities of daily living without significant impairment (she just needed to "take it easy"), the court found that she did not meet the ADA's definition of disability and thus was not covered by the statute.

Given previous precedent, the result in this case is not surprising. Plaintiff did not put on proper evidence of how her impairment affected her daily life, and did not rebut evidence that there was no affect on her daily life. The Sixth Circuit's ruling was based on evidence about her workplace performance. Even that evidence was problematic because at times she was restricted from doing any work, which would prevent her from being "otherwise qualified" under the ADA. The Supreme Court makes it clear that duty to do an individualized determination falls on plaintiffs as well as defendants, so that to prevail under the ADA the plaintiff must put on expert testimony on the specific ways in which the impairment significantly affects the activities of daily life.