Labor Law -- 2002



Toyota Motor Manufacturing, Kentucky, Inc. v. Williams   (U.S. Supreme Court)

Scope of ADA coverage

The Supreme Court unanimously ruled on 1/8/02 that an individual cannot establish the existence of a disability under the Americans with Disabilities Act by simply showing that she is restricted from performing certain elements of a single job.

The plaintiff in this case had carpal tunnel syndrome and tendinitis, and the lower court had found that Williams could be considered disabled due to her inability to perform certain manual tasks associated with her job. On appeal, the Supreme Court ruled that the inability to perform a single job - or, as here, elements of a single job - cannot be the basis for finding a disability. Rather, there must be "an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people's daily lives. The impairment's impact must also be permanent or long-term."

Moreover, the Court said that an individual can't prove a disability merely by submitting evidence of a medical diagnosis of an impairment. Instead, there must be evidence that the limitation caused by their impairment in terms of their own experience is substantial. Each person must show that central activities in his or her daily life are severely restricted.

On March 5, the NAM filed an amicus brief in the Supreme Court supporting Toyota’s petition to review this case. The brief, written by Peter Susser and Joseph Schuler at Littler Mendelson, highlights the erroneous result and the serious consequences for manufacturers if it is allowed to stand. The petition for cert. was granted, and the NAM filed a brief on the merits on 6/28/01, along with the Equal Employment Advisory Council.