Toyota Motor Manufacturing, Kentucky, Inc. v. Williams
The Court ruled that an appeals court used the wrong test for deciding whether a car-plant worker's carpal tunnel syndrome counted as a disability under the Americans with Disabilities Act, because it looked only at whether she could do the specific manual tasks required by her job rather than tasks central to everyday life.
The decision sets a stricter, more demanding standard for proving a manual-task disability under the ADA, requiring workers to show they cannot perform activities important to most people's daily lives -- like bathing, dressing, or housework -- not just tasks tied to their particular job.
“We therefore hold that to be substantially limited in performing manual tasks, an individual must have an impairment that prevents or severely restricts the individual from doing activities that are of central importance to most people’s daily lives.”
The Court's core holding on what counts as a substantial limitation in performing manual tasks under the ADA.
How it got here: A federal trial court granted summary judgment to the employer; the Sixth Circuit reversed in part, granting the worker partial summary judgment on disability status; the employer sought Supreme Court review.
The Case in Depth
What happened
Williams worked on an assembly line at a Kentucky auto plant, where repetitive tool use caused carpal tunnel syndrome and related arm and shoulder injuries. After returning to work following an earlier settled lawsuit, she was assigned rotating inspection duties that aggravated her condition. When the company required her to continue a physically demanding task despite her requests for accommodation, she eventually stopped working and was fired for poor attendance, prompting her to sue under the ADA.
The question before the Court
Was an assembly-line worker's carpal tunnel syndrome and related injuries severe enough to count as a "disability" under the ADA because they limited her ability to perform manual tasks?
The Court's answer
Not entirely -- the Court held that the worker's carpal tunnel syndrome and related injuries were not automatically a disability under the ADA just because she couldn't perform certain job-specific manual tasks. To be "substantially limited" in performing manual tasks, a person must show her impairment prevents or severely restricts activities central to most people's daily lives, such as bathing, dressing, or doing household chores -- not merely tasks tied to a particular job.
Because the appeals court had focused narrowly on her inability to do specialized assembly-line tasks and had ignored evidence that she could still handle everyday personal and household activities, the Court found it used the wrong test. It reversed the appeals court's grant of partial summary judgment to the worker and sent the case back for reconsideration under the corrected standard, leaving her other disability theories undecided.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Workers claiming ADA protection for repetitive-motion injuries like carpal tunnel syndrome will now face a tougher standard: they must show their impairment limits everyday activities, not just job-specific tasks. Employers gain a clearer, narrower yardstick for evaluating disability claims, and many workers whose limitations are confined to specialized job duties may find it harder to qualify as disabled.
What changes now
The case goes back to the Sixth Circuit, which must reconsider whether the worker was disabled under the corrected legal standard, focusing on her ability to perform everyday tasks rather than job-specific ones. The Supreme Court did not decide whether she was substantially limited in lifting or working, or whether she had a record of or was regarded as having a disability -- those issues remain open for the lower courts to address on remand.
What this does not decide
The Court did not decide whether the worker was disabled under other theories she raised, including substantial limitation in lifting or working, having a record of a disability, or being regarded as disabled. It also expressly avoided deciding whether working itself qualifies as a major life activity under the ADA.
How the Court got there
The legal reasoning, step by step
- The Court read the ADA's definition of disability closely, explaining that 'substantially limits' means a considerable or large degree of restriction, and 'major life activities' means activities of central importance to daily living, like walking, seeing, and hearing.
- Applying that standard to manual tasks, the Court held that a person must show their impairment prevents or severely restricts them from performing activities central to most people's daily lives -- not just tasks unique to their job -- and that the limitation must be permanent or long-term.
- The Court rejected the lower court's approach of asking whether the worker could perform a 'class' of manual activities tied to her specific job, explaining that this class-based test comes from the separate major life activity of working, not from performing manual tasks generally, and that job-specific duties are not necessarily important to daily life.
- The Court also found the lower court had wrongly ignored evidence that the worker could still perform everyday activities like personal hygiene and household chores, reasoning that such tasks are exactly the kind of activities relevant to whether someone is substantially limited in performing manual tasks.
- Reviewing the record under the corrected standard, the Court concluded the evidence -- showing the worker could still bathe, dress, garden, and do light housework -- did not establish as a matter of law that she was substantially limited in performing manual tasks.
Doctrinal impact
Cases affected by this decision
Distinguishes Sutton v. United Air Lines, Inc. (527 U. S. 471)
Clarified that Sutton's 'class of jobs' test applies only to the major life activity of working, not manual tasks.
Reaffirms Albertson's, Inc. v. Kirkingburg (527 U. S. 555)
Relied on its requirement that disability be assessed individually, based on actual experienced limitations.
Reaffirms Bragdon v. Abbott (524 U. S. 624)
Followed its approach of construing ADA terms consistent with prior Rehabilitation Act regulations.