KEY TAKEAWAYS: Employees with disabilities may be entitled to reasonable accommodations even if they can perform the essential functions of their job without an accommodation. Ability to perform the essential functions of the job is relevant to a failure-to-accommodate claim, but it is not dispositive. In a recent Second Circuit decision from March, Tudor v. Whitehall Central School District , the court clarified the broad scope of workplace accommodation protections under the Americans with Disabilities Act (ADA). Specifically, the court ruled that employees with disabilities may be entitled to reasonable accommodations even if they can perform the essential functions of their job without one. In Tudor, plaintiff appealed a decision from the U.S. District Court for the Northern District of New York granting summary judgment in favor of the defendant on a failure-to-accommodate claim brought pursuant to the ADA. The lower court ruled that an employee’s...
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Second Circuit Adopts Broad Reading of ADA Protections in Recent Workplace Accommodations Case
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In a decision issued on March 25, 2025, the Second Circuit Court of Appeals clarified the s cope of protections under the Americans with Disabilities Act (ADA) regarding workplace accommodations. The court’s ruling in Tudor v. Whitehall Central School District establishes that employees with disabilities may be entitled to reasonable accommodations, even if they can perform the essential functions of their jobs without them. Quick Hits In a decision on March 25, 2025, the Second Circuit Court of Appeals ruled that employees with disabilities may be entitled to reasonable accommodations under the ADA even if they can perform their jobs’ essential functions without them. The case involved a high school teacher with PTSD who was denied brief afternoon breaks, leading the Second Circuit to emphasize the ADA’s broader support for employee well-being and inclusion. The Second Circuit’s ruling clarifies that under the ADA, a “qualified individual” may be entitled to reasonable acco...