Law School Case Brief
Toyota Motor Mfg., Ky. v. Williams - 534 U.S. 184, 122 S. Ct. 681 (2002)
The Americans with Disabilities Act of 1990, 42 U.S.C.S. § 12101 et seq., defines a qualified individual with a disability as an individual with a disability who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires. 42 U.S.C.S. § 12111(8). In turn, a disability is: (1) a physical or mental impairment that substantially limits one or more of the major life activities of such individual; (2) a record of such an impairment; or (3) being regarded as having such an impairment. 42 U.S.C.S. § 12102(2).
In 1997, Toyota Motor Manufacturing, Kentucky, Inc. terminated Ella Williams, citing her poor attendance record. Subsequently, claiming to be disabled from performing her automobile assembly line job by carpal tunnel syndrome and related impairments, Williams sued Toyota for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA).
Did the Court of Appeals use the proper standard in determining whether an employee was disabled under the ADA due to carpal tunnel syndrome?
In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that the Court of Appeals did not apply the proper standard in making its determination because it analyzed only a limited class of manual tasks and failed to ask whether Williams's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives. The Court also reasoned that for the purposes of the ADA, an impairment's impact must also be permanent or long-term. "Given large potential differences in the severity and duration of the effects of carpal tunnel syndrome, an individual's carpal tunnel syndrome diagnosis, on its own, does not indicate whether the individual has a disability within the meaning of the ADA," wrote Justice O'Connor for the Court.
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