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Dissatisfaction Is Not Discrimination: Fourth Circuit Affirms Employer Discretion Over Reasonable Accommodations

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In a significant decision for employers navigating disability accommodation obligations under the Americans with Disabilities Act (ADA), the U.S. Court of Appeals for the Fourth Circuit in Redding v. Noem , No. 24-1141 (March 3, 2026), reaffirmed the principle that the interactive process does not guarantee employees their desired outcomes, and “dissatisfaction [with a reasonable accommodation] does not amount to a failure to accommodate.” 00:00 24:53 Quick Hits While the ADA’s interactive process is a collaborative dialogue, employers retain ultimate discretion over the choice of effective accommodations. Employees may not redefine the essential functions of jobs or unilaterally dictate the terms of accommodations . Although reassignment is the accommodation of last resort, it satisfies the employer’s reasonable accommodation obligation. Background In this case, the employee worked as a federal air marshal for the Transportation Security Administration (TSA) for more than seven years....

TSA Proposes Moving REAL ID Compliance for Domestic Fliers to 2027

  The Transportation Security Administration (TSA) has proposed delaying enforcement of the REAL ID requirement for passengers of domestic airlines to give travelers two more years to update to REAL ID-compliant identifications. The proposal is   open for comments   until Oct. 15, 2024. The REAL ID Act was passed by Congress based on the 9/11 Commission’s recommendations. Full enforcement for domestic air travelers was scheduled to go into effect in May 2025. That date  likely will be pushed to 2027 . Under REAL ID security regulations, all passengers 18 years and over on domestic airlines would need a REAL ID-compliant identification to board. Although various documents are REAL ID-compliant, the key document became state-issued REAL ID-compliant driver’s licenses. Approximately 53 percent of the U.S. population had REAL ID-compliant identifications in 2023 when the deadline was pushed to May 2025. As of now, only 56 percent of the population have REAL ID-compliant ...