00-1089 Toyota Motor Mfg. v. Williams

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The Sixth Circuit erred in suggesting that, in order to prove a substantial limitation in the major life activity of performing manual tasks, a plaintiff must show that her manual disability involves a “class” of manual activities, and that those activities affect the ability to perform tasks at work. Nothing in the ADA’s text, this Court’s opinions, or the regulations suggests that a class-based framework should apply outside the context of the major life activity of working. While the Sixth Circuit addressed the different major life activity of performing manual tasks, its analysis erroneously circumvented Sutton, supra, at 491, by focusing on respondent’s inability to perform manual tasks associated only with her job. Rather, the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people’s daily lives. Also without support is the Sixth Circuit’s assertion that the question whether an impairment constitutes a disability is to be answered only by analyzing the impairment’s effect in the workplace. That the Act’s “disability” definition applies not only to the portion of the ADA dealing with employment, but also to the other provisions dealing with public transportation and public accommodations, demonstrates that the definition is intended to cover individuals with disabling impairments regardless of whether they have any connection to a workplace. Moreover, because the manual tasks unique to any particular job are not necessarily important parts of most people’s lives, occupation-specific tasks may have only limited relevance to the manual task inquiry. In this case, repetitive work with hands and arms extended at or above shoulder levels for extended periods, the manual task on which the Sixth Circuit relied, is not an important part of most people’s daily lives. Household chores, bathing, and brushing one’s teeth, in contrast, are among the types of manual tasks of central importance to people’s daily lives, so the Sixth Circuit should not have disregarded respondent’s ability to do these activities.”

Local Effect: The decision is consistent with current Seventh Circuit law, EEOC v. Rockwell Int’l Corp., 243 F.3d 1012 (7th Cir. 2001).

Certiorari to the United States Court of Appeals for the Sixth Circuit, 224 F.3d 840, reversed and remanded.