Second Circuit Ruling: Employers Must Accommodate Workers Even If They Can Perform Essential Job Functions Without Accommodation

Real World Impact: The Second Circuit Court of Appeals recently held that absent an undue hardship, an employer must provide a reasonable accommodation to a qualified, disabled employee regardless of whether the employee can perform her essential job functions without an accommodation. The court's ruling in Tudor v. Whitehall Central School District changes our understanding of the Americans with Disabilities Act's (ADA's) requirements regarding when a reasonable accommodation is necessary, at least in the Second Circuit (which covers Connecticut, New York, and Vermont).

Background on Tudor v. Whitehall Central School District

Angel Tudor, a high school math teacher working for approximately twenty years at Whitehall Central School District, brought a failure to accommodate claim pursuant to the ADA before the United States District Court for the Northern District of New York. Tudor is diagnosed with PTSD, which manifests as symptoms affecting Tudor's