Second Circuit Clarifies ADA: Reasonable Accommodations Include Well-Being

On March 25, the Second Circuit Court of Appeals’ ruling in Tudor v. Whitehall Central School District established that employees with disabilities may be entitled to reasonable accommodations, even if they can complete their jobs without them.

Tudor v. Whitehall Central School District 

Angel Tudor, a high school teacher in New York, diagnosed with post-traumatic stress disorder (PTSD), requested brief afternoon breaks as a reasonable accommodation to help manage her condition. However, the school district denied her request, so she filed a lawsuit under the Americans with Disabilities Act (ADA) for failure to accommodate. Since Tudor admitted she could still perform the functions of her job, although under significant stress and harm, the lower court dismissed her claim. The Second Circuit Court of Appeals reversed its decision. The court emphasized that the ADA mandates reasonable accommodations not only to enable job performance but also to promote employee well-being and inclusion in the workplace.

Breaking Down the Second Circuit’s Ruling

The ADA’s Definition Matters

The ADA says a “qualified employee” is someone who can do the main parts of their job, with or without help. The Second Circuit explained that this means employers still need to consider giving accommodations, even if the employee can technically do the job without them. Employers should review and update their ADA policies to ensure that they align with the current legal standards.

Accommodation is About Inclusion, Not Just Enablement

In the past, accommodations were seen as helping disabled employees meet basic job requirements. However, the Second Circuit's opinion shifts the focus to ensuring fair working conditions, addressing issues like stress, emotional safety, or worsened medical symptoms, even if job performance is not directly affected.

Since managers and supervisors often receive accommodation requests first, provide them with training on ADA obligations and effective, empathetic communication. For mid-size to large organizations, a cross-functional team, including HR, legal, facilities, and occupational health representatives, can evaluate complex accommodation requests.

Undue Hardship is the Only Exception

Employers do not have to grant every accommodation request, but they must show a clear "undue hardship,” meaning it would be difficult or expensive to accommodate, considering their size, resources, and operations. This creates a high standard for denying accommodations and places the burden of proof on the employer. Employers should track all accommodation requests, resolutions, and follow-ups to ensure consistency, fairness, and legal defensibility.

The Second Circuit’s ruling is consistent with decisions from other circuit courts, reinforcing the principle that employers must evaluate reasonable accommodation requests even when an employee is technically able to perform their job without them. The Tudor decision confirms that the ADA’s protections do extend to accommodations that improve the overall workplace environment.