Second Circuit: Employers May Be Required to Provide Accommodations to Employees, Even if They Can Perform the Job Without It
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APPLIES TO Employers with Employees in CT, NY and VT |
EFFECTIVE March 25, 2025 |
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Discussion:
On March 25, 2025, the Second Circuit Court of Appeals issued an opinion in Tudor v. Whitehall Central School District, finding that employees with disabilities may be entitled to reasonable accommodations under the Americans with Disabilities Act (ADA), even if they can perform the essential functions of their jobs without them.
In this case, a high school teacher was diagnosed with post-traumatic stress disorder (PTSD), and requested brief afternoon breaks to manage her condition. The school district denied her request, leading her to file a lawsuit alleging a failure to accommodate under the ADA. The lower court dismissed her claim, but the Second Circuit overturned this decision, emphasizing the ADA’s broader support for employee well-being and inclusion.
Under the ADA, a “qualified individual” is someone who can perform the essential functions of their job with or without reasonable accommodation. The court said this means that employers must consider reasonable accommodations to enhance an employee’s workplace experience, not just those necessary for job performance. The decision aligns with similar rulings from other circuits, underscoring the importance of employer compliance with the ADA’s broad protections.
In light of this ruling, employers should reassess their accommodation policies to ensure they are providing adequate support for employees with disabilities, even if those employees can technically fulfill their job duties without accommodation. This may include considering accommodations that enhance overall workplace experience and employee well-being, rather than focusing solely on those essential for job performance.
Action Items
- Review workplace accommodation policies and practices for compliance.
- Have appropriate personnel trained on reasonable accommodation requirements.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase