Those tasks aren't important--the Supreme Court limits application of the ADA.

• Author: Silverman, Scott T.

In Toyota Motor Mfg., Ky., Inc. v. Williams, 122 S. Ct. 681 (2002), the Supreme Court held that the determination of whether an individual's physical impairment substantially limits the major life activity of performing manual tasks, thereby qualifying as a "disability" under the Americans with Disabilities Act (ADA), must be made by analyzing the physical impairment's impact on tasks that are of central importance to most people's daily lives. (1) Accordingly, the analysis cannot focus on a limited number of manual tasks that are tangential to the daily functioning of most individuals. (2) In so holding, the Supreme Court severely limited the number of employees subject to the protections of the ADA.

The plaintiff in Toyota Motor worked on a Quality Control Inspection Operations (QCIO) team in defendant's automobile manufacturing plant. (3) Plaintiff's duties involved visually inspecting painted cars for scratches, chips, or any other flaws that may have occurred during the assembly or painting process. (4) In addition, plaintiff was required to wipe each painted car with a glove as it moved along a conveyor. (5) Plaintiff rotated between these jobs on a weekly basis. (6) After plaintiff rotated between these duties for approximately two years, another job was added to plaintiff's rotations in the fall of 1996. This duty required her to apply highlight oil, with a sponge attached to a block of wood, to the hood, fender, doors, rear quarter panel and trunk of passing cars. After wiping the car with the oil, plaintiff was required to visually inspect for flaws. (7) This job required plaintiff to hold her hands and arms up around shoulder height for several hours at a time. (8) A short while after this job was added to plaintiff's rotations, she began to experience pain in her neck and shoulders. She was diagnosed by defendant's in-house medical service with various conditions that affected her shoulder blades, forearms, and nerves leading to the upper extremities. (9)

Plaintiff requested that defendant accommodate her by returning her to the first two jobs she performed, without duties related to the third job. (10) According to Plaintiff, defendant refused this request and forced her to continue working in the third job, which caused exacerbation of her injuries. (11) After receiving a right to sue letter from the EEOC, plaintiff filed suit, alleging that defendant had violated, inter alia, the ADA, by failing to reasonably accommodate her disability when she requested a return to her first two jobs. (12) Plaintiff's complaint alleged that she was disabled, because she was substantially limited in the major life activity of, inter alia, manual tasks. (13) Defendant filed a motion for summary judgment, and plaintiff filed a motion for partial summary judgment that she was disabled under the ADA. The district court granted final summary judgment for defendant, reasoning, inter alia, that plaintiff's claim that she was substantially limited in manual tasks was barred by her insistence that she could perform the tasks of her first two jobs. (14)

Plaintiff appealed to the Sixth Circuit Court of Appeals, which reversed the district court's ruling on whether plaintiff was disabled at the time she sought an accommodation. (15) According to the Sixth Circuit, in order for plaintiff to demonstrate that she was substantially limited in the ability to perform manual tasks, she had to "show that her manual disability involved a class of manual activities affecting the ability to perform tasks at work." (16)

The Sixth Circuit held that plaintiff satisfied...