Toyota Motor Mfg., Ky., Inc. v. Williams, 534 U.S. 184 (2002)

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certiorari to the united states court of appeals for the sixth circuit

No. 00-1089. Argued November 7, 2001—Decided January 8, 2002

Claiming to be unable to perform her automobile assembly line job because she was disabled by carpal tunnel syndrome and related impairments, respondent sued petitioner, her former employer, for failing to provide her with a reasonable accommodation as required by the Americans with Disabilities Act of 1990 (ADA), 42 U. S. C. 12112(b)(5)(A). The District Court granted petitioner summary judgment, holding that respondent's impairment did not qualify as a "disability" under the ADA because it had not "substantially limit[ed]" any "major life activit[y]," 12102(2)(A), and that there was no evidence that respondent had had a record of a substantially limiting impairment or that petitioner had regarded her as having such an impairment. The Sixth Circuit reversed, finding that the impairments substantially limited respondent in the major life activity of performing manual tasks. In order to demonstrate that she was so limited, said the court, respondent had to show that her manual disability involved a "class" of manual activities affecting the ability to perform tasks at work. Respondent satisfied this test, according to the court, because her ailments prevented her from doing the tasks associated with certain types of manual jobs that require the gripping of tools and repetitive work with hands and arms extended at or above shoulder levels for extended periods of time. In reaching this conclusion, the court found that evidence that respondent could tend to her personal hygiene and carry out personal or household chores did not affect a determination that her impairments substantially limited her ability to perform the range of manual tasks associated with an assembly line job. The court granted respondent partial summary judgment on the issue of whether she was disabled under the ADA.

Held: The Sixth Circuit did not apply the proper standard in determining that respondent was disabled under the ADA because it analyzed only a limited class of manual tasks and failed to ask whether respondent's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives. Pp. 193-203.

(a) The Court's consideration of what an individual must prove to demonstrate a substantial limitation in the major life activity of performing manual tasks is guided by the ADA's disability definition.

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