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ARTICLE · 25 APRIL 2025

The New Standard For Reasonable Accommodations In The Second Circuit

Seyfarth Shaw LLP
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The Second Circuit Court of Appeals (the "Second Circuit") recently decided Tudor v. Whitehall Central School District, which changes the landscape of reasonable accommodations...

United StatesEmployment and HR
Tatiana M. Sterling
Tatiana M. Sterling
Ashley N. Casey
Ashley N. Casey
Marlin Duro-Martinez
Marlin Duro-Martinez
William Perkins
William Perkins
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The Second Circuit Court of Appeals (the "Second Circuit") recently decided Tudor v. Whitehall Central School District, which changes the landscape of reasonable accommodations, within the Circuit, under the Americans with Disabilities Act ("ADA"). The Second Circuit followed the trend set by the First, Fifth, Sixth, Ninth, Tenth, Eleventh, and D.C. Circuits in holding that an employee with a disability may qualify for a reasonable accommodation even if they can perform the essential functions of their job without an accommodation.

Background:

Angel Tudor ("Tudor"), a teacher who worked for Whitehall Central School District ("Whitehall") for nearly 20 years, had a longstanding history of post-traumatic stress disorder ("PTSD") following an incident of sexual harassment and assault by a supervisor at a prior employer. The PTSD caused severe psychiatric symptoms for which Tudor sought psychiatric help and was prescribed several medications.

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