Ella Williams worked on a team in Toyota’s Quality Control Inspection Operations (“QCIO”).  QCIO teams performed four different tasks, and Ms. Williams’ team performed two of the four tasks.  In 1996, Toyota determined that it would require QCIO team members to be able to rotate through all four different task areas.  Shortly after Ms. Williams began performing the additional tasks required by the new policy she experienced pain in her neck and shoulders.  Toyota’s in-house doctor diagnosed her with carpal tunnel syndrome and related impairments.  On December 6, 1996, Williams’ treating doctor placed her on a “no-work-of-any-kind” restriction, and on January 27, 1997, Toyota terminated her employment citing her poor performance record.
Ms. Williams filed a complaint against Toyota stating claims under the Americans with Disabilities Act (“ADA”) and Kentucky’s Civil Rights Act.  She alleged that Toyota had breached these laws because it failed to reasonably accommodate her disability and because it terminated her employment.  The federal district court, rejecting Williams’ arguments that “gardening, doing housework, and playing with children are major life activities,” granted Toyota’s summary judgment motion on the basis that Ms. Williams’ physical impairment “did not quality as a disability because it had not ‘substantially limit[ed]’ any ‘major life activit[y].’”  Toyota Motor Manufacturing Kentucky, Inc. v. Williams, 122 S.Ct. 681, 688  (2002), 2002 WL 15402, *5 (citing the district court decision and applicable statute).  The Court of Appeals for the Sixth Circuit overruled the district court’s decision on the basis that Ms. Williams’ impairment substantially limited her ability to perform manual tasks associated with an assembly line job.  Id. at 688, *6.  The Supreme Court granted certiorari to consider the “proper standard for assessing whether an individual is substantially limited in performing manual tasks.”  Id. at 689, *6.
The Supreme Court begins its analysis by recognizing that “merely having an impairment does not make one disabled for the purposes of the ADA.”  Id. at 690, *8.  The question of whether impairment constitutes a disability under the ADA is to be answered by consideration of the impact of the impairment on a person’s daily life. Id. 693, *12.  “Occupation-specific tasks may have only limited relevance to the manual task inquiry.”  Id.  Because she admitted that she could perform some manual tasks at Toyota, she was not substantially limited in performing the major life activity of working because she was not significantly restricted in her ability to perform either a class of jobs or a range of jobs in various classes.  Id. at 693, *11.  The Supreme Court concluded that while Ms. Williams’ impairment affected her ability to perform some manual tasks required by her former job at Toyota, these tasks are “not an important part of most people’s daily lives.”  Id. 693, *12.   The Supreme Court noted that “household chores, bathing, and brushing one’s teeth are among the types of manual tasks of central importance to people’s daily lives, and should have been part of the assessment of whether respondent was substantially limited in performing manual tasks.”  Id. at 693, *12.  Williams was able to “brush her teeth, wash her fact, bath, tend her flower garden, fix breakfast, do laundry, and pick up around the house,” and while her impairments “caused her to avoid sweeping, to quit dancing, to occasionally seek help dressing, and to reduce how often she plays with her children, gardens and drives long distances,” these changes to her life “did not amount to such severe restrictions in the activities that are central importance to most people’s daily lives that they establish a manual-tasks disability as a matter of law.”  Id.  at 694, *12. 

The Supreme Court’s decision in Toyota clarifies the definition of “disabled” under the ADA.  This decision requires a court to consider not only the employee’s ability to perform his or her job, but the impact of the impairment on the person’s daily life.  An employee may not prove disability status by merely presenting evidence that he or she cannot perform functions associated with their job.  Under Toyota, to establish manual-task disability under the ADA an employee must prove that his impairment substantially impairs his ability to perform tasks that are an important part of most people’s daily lives or that the impairment substantially limits his ability to perform a class of jobs or a broad range of jobs in various classes.