"The Trial of Rosie O'Neill" has a background player in a wheelchair.  I have
a vague memory that "Lou Grant" did also.
 
Madlyn Rhue performed substantial roles in a wheelchair on television a few
years ago when she was disabled by something like multiple sclerosis.
Arthritis, I think, was the ailment that confined Lionel Barrymore to a wheel-
chair in the Dr. Kildare movies of the thirties