Toyota Motor Manufacturing, Kentucky, Inc. v. Williams

Background

A woman who worked on an automobile assembly line told her employer she could no longer use certain tools or do tasks that required holding her arms up because of carpal tunnel syndrome and related shoulder and nerve problems. After medical restrictions, the company moved her into quality-inspection jobs, including one that required wiping cars with hands raised. She asked to be kept on less physical inspection tasks, was later put on a no-work restriction, and then was fired for poor attendance. She sued her former employer under the Americans with Disabilities Act, arguing her impairments substantially limited her ability to perform manual tasks. The District Court ruled for the employer; the Sixth Circuit reversed, finding she was disabled in performing manual tasks.

Reasoning

The Court addressed whether being unable to do certain job-specific manual tasks amounts to a disability under the ADA. It said the right question is whether the impairment prevents or severely restricts activities that are central to most people’s daily lives, not whether it prevents performing particular tasks tied to a specific job. The Court emphasized that the limit must be long-term or permanent, and that a medical diagnosis alone is not enough. Evidence about everyday activities like bathing, dressing, housework, or child care is relevant. Because the Sixth Circuit focused on assembly-line tasks instead of daily-life tasks, the Court reversed that decision.

Real world impact

The ruling makes it harder for workers to claim ADA protection based only on inability to do specialized job duties; they must show serious, long-term limits on common daily activities. The case was returned to lower courts for further proceedings; other theories in the case were left open.