In the recently issued decision in McDaniel v. Wilkie,
the U.S. District Court for the Northern District of Ohio
considered whether telecommuting constitutes a reasonable
accommodation under the Americans with Disabilities Act (ADA). The
short answer is that it can constitute a reasonable accommodation
if it would enable an employee to satisfactorily perform the
essential functions of his or her position and does not impose an
undue burden on the employer.
In this case, an employer initially permitted an employee to
telecommute four days per week. When the employee's
productivity declined, the employer informed her that she must
improve her productivity or her telecommuting privileges would be
suspended. One week later, the employee requested full-time
telecommuting as an accommodation for her alleged disability. The
employer denied her request and revoked her telecommuting
arrangement altogether. The employee resigned and claimed that her
employer subjected her to a
