Toyota Motor MFG v. WilliamsPRESENTED BY: SAMUEL E. DUNHAM

VALDOSTA STATE UNIVERSITY

Americans with Disabilities Act (1990)

Important considerations for the Act:◦ A disability must be present

◦ Physical or mental◦ The impairment must substantially limit one or more major life activities◦ A history or record of the disability should be evident

◦ Or should be perceived by others to have a disability

Case Background Law of Concern: Americans with Disabilities Act of 1990 (ADA) Petitioner: Toyota Motor MFG Respondent: Ella Williams The Situation

The First Two RulingsTHE DISTRICT COURT

Favored: Toyota Motor MFG

Reason 1: Williams’ injury had not “substantially” hindered her from ANY major life activity

Reason 2: No evidence of any “substantially” hindering impairment

Not covered under the ADA

THE COURT OF APPEALS

Favored: Williams

Reason: Her impairment was determined to have hindered her from doing the tasks that she would do on the job

Covered under the ADA

The Supreme Court The Issue: Should Williams have been covered under the ADA considering that her disability hindered her from doing the manual labor that was required of her job?

Favored: Toyota Motor MFG

The Vote: 9-0

The Supreme Court Reasoning The appropriate standard was not used by the Court of Appeals Importance of the word “substantially” Impairments must be long-term or permanent The role of evidence

Implications of the Ruling Manual tasks associated with everyday life are the important consideration, not manual tasks associated with the job

The purpose of the ADA “Case-by-case” Considerations Is the definition of a “disability” adequate? Revisit of the ADA by Congress in future years

Discussion What are your thoughts concerning the case ruling? In your opinion, would the ADA be “stronger” by classifying a disability based on manual tasks performed on the job instead of by manual tasks associated with everyday life? Explain.

Going into your professional field, what concerns (if any) do you have about ADA case determinations being made on a “case-by-case” basis?

ADA Amendments Act (2008) - ADAAA

Important changes to the ADA◦ “Disability” - broader and more inclusive◦ More discrimination focused, less person focused◦ The role of mitigating measures ◦ Major life activities & major bodily functions◦ What has to be proven

References Mook, J.R. (2002). Toyota v. Williams: The disability analysis continues. Employee Relations Law Journal, 28(1), 25.

Toyota v. Williams. 534 U.S. 184. (2002). Retrieved from Academic Search Complete Database.

Vargas, C. (2002). SELECT RECENT COUT DECISIONS: Disability law: Substantial limitations under the Americans with Disabilities Act – Toyota Motor Manufacturing, Kentucky, Inc. v. Williams, 122 S. Ct. 681 (2002). American Journal of Law & Medicine, 28(1), 124.