From Household Bathrooms to the Workplace: Bringing the Americans with Disabilities Act Back to Where It Belongs: An Analysis of Toyota Motor Manufacturing V. Williams

By Ulgen, Argun M. | Fordham Urban Law Journal, January 2003 | Go to article overview

From Household Bathrooms to the Workplace: Bringing the Americans with Disabilities Act Back to Where It Belongs: An Analysis of Toyota Motor Manufacturing V. Williams


Ulgen, Argun M., Fordham Urban Law Journal


INTRODUCTION

Ella Williams has endured the following impairments over the past ten years: bilateral carpal tunnel syndrome, (1) myotendinitis and myositis bilateral, and thoracic outlet compression. (2) Williams's carpal tunnel syndrome could lead to muscle atrophy and extreme sensory deficits. (3) Her other conditions are equally unpleasant: myotendinitis bilateral perscapular is an inflammation of the muscles and tendons around both shoulder blades; (4) myotendinitis and myositis bilateral affects the forearms by causing median nerve irritation, (5) and thoracic outlet compression is characterized by pain in the nerve leading to the upper extremities. (6) As a result of these afflictions, Williams needs help getting dressed. (7) She cannot drive long distances with her family. (8) She cannot garden as much as she would like, has quit dancing, and must limit her participation in other recreational activities. (9) She cannot sweep the floors of her home. (10) Most importantly, Williams must limit the time she spends playing with her children. (11)

Although Ella Williams's impairments resulted in several changes in her lifestyle, she still wanted to be a productive citizen in the workforce. (12) Williams's employer, Toyota Motor Manufacturing, made a small adjustment to her work schedule, and assigned Williams to tasks that did not require any activity that could worsen her impairments. (13) While she was not able to frequently lift objects weighing ten pounds or more, constantly extend her wrists or elbows, maintain her arms above her shoulders for extended periods of time, or use vibratory tools, she proved valuable in other jobs within the workplace. (14) For three years, Williams was assigned to the assembly line to scan products for flaws. (15) Throughout that time, her employer said her performance was Satisfactory. (16)

In 1996, however, Toyota Motor Manufacturing revamped its policies to require those who worked in Williams's division to do certain physical tasks. (17) Those tasks worsened Williams's impairments. (18) Williams took several days off from work due to severe pain. (19) Eventually, according to Williams, she was fired because of her inability to perform these tasks. (20) In response, she sued Toyota Motor Manufacturing for discrimination under the Americans with Disabilities Act ("ADA" or "Act"). (21)

Under the ADA, Toyota Motor Manufacturing is required to provide Williams with "reasonable accommodations" (22) for her "known physical or mental limitations," (23) if Williams is "an otherwise qualified individual with a disability," (24) provided that the accommodation does not pose an "undue hardship" on the business. (25) In Toyota Motor Manufacturing v. Williams, (26) the Supreme Court had to decide whether Williams was disabled under the ADA as a matter of law. (27) Justice Sandra Day O'Connor wrote the opinion for a unanimous Court, holding that she was not. (28) The effect of this decision is that Williams, a seven-year Toyota employee, may lose her job permanently. The severe combination of impairments she has incurred has not been interpreted as a disability under the ADA. Justice O'Connor's "strict" interpretation (29) of the ADA may bar many employees with impairments similar to Williams who request reasonable workplace accommodation from pursuing lawsuits under the ADA because they do not fit within the ADA definition of being disabled. (30)

In deciding that Williams was not disabled under the ADA, Justice O'Connor was most concerned with deferring to the "legislative findings and purposes that motivate the Act." (31) Recognizing that Congress cited forty-three million people as being disabled, (32) Justice O'Connor justified her strict interpretation of the ADA as follows: "If Congress intended everyone with a physical impairment that precluded the performance of some isolated, unimportant, or particularly difficult manual task to qualify as disabled, the number of disabled Americans would surely have been much higher. …

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