Does "Reasonable Accommodation" Have Nothing To Do With "Essential Job Functions"?

Since the original passage of the Americans With Disabilities Act ("ADA") in 1990, employers have come to know that they generally have an obligation to reasonably accommodate a qualified individual with a disability, presumably to enable him or her to perform the essential functions of the job. Indeed, with the more recent 2008 passage of the Americans With Disabilities Amendments Act, that obligation has received greater attention due to the amended law's purpose of bringing more individuals within the definition of "qualified individual with a disability."

Under either iteration of the disability law, an oft-shared understanding by employers has been that their obligation to reasonably accommodate an employee only applies to accommodations that enable the worker to perform the essential functions of the job – but not necessarily grant accommodations that have nothing to do with an individual's actual job duties. A recent decision from the United States Court