First Circuit Recognizes Retaliation Claim for a Requested Reasonable Accommodation Under the ADA

A recent decision from the First Circuit Court of Appeals highlights a complex, constantly-evolving area of the Americans with Disabilities Act with which employers constantly struggle: the reasonable accommodation process and the often tense, complicated aftermath.

In Wright v. CompUSA, Inc., the First Circuit tackled the issue of whether requesting a reasonable accommodation is a protected activity under the ADA, and thus sufficient to support a subsequent retaliation claim. Mr. Wright had worked at CompUSA’s Brighton, Massachusetts facility as a Direct Sales Manager from 1996 through his termination in August 1998. In Spring 1997, Mr. Wright was diagnosed with Attention Deficit Disorder ("ADD") and began taking Ritalin to control his ADD. In June 1998, a new general manager, Mr. Caughman, was assigned to the Brighton store. The plaintiff claimed that Mr. Caughman’s managerial style caused him severe stress and anxiety, which, in turn, exacerbated