No Nexus Is Required Between Requested Accommodation and Job Functions Under The ADA

In a significant opinion, the U.S. Court of Appeals for the Fifth Circuit in Feist v. State of Louisiana, No. 12-31065 (5th Cir. Sept. 16, 2013), held that the ADA does not require a link between a requested accommodation and the employee’s essential job functions for the employee to state a claim of unlawful discrimination. More after the break.

According to the opinion, the plaintiff, a former assistant attorney general for the Louisiana Department of Justice, suffered from osteoarthritis in her knee. As a result of her osteoarthritis, which was a “disability,” Plaintiff asked for reserved on-site parking. Plaintiff’s employer refused her request. Plaintiff sued under the ADA as a result. The district court granted summary judgment to the employer, noting the plaintiff’s failure to explain how the denial of on-site parking limited her ability to perform the “essential functions” of the job.

The issue on appeal was whether the employer was obligated to provide only an accommodation directly related to the essential functions of the job or whether the ADA is more expansive, requiring an employer to provide an accommodation to ensure equal benefits and privileges, without relation to the essential functions of the job.

The Court of Appeals reversed summary judgment, finding that the District Court ruled the district court erred by requiring a nexus between the employee’s requested accommodation, a reserved parking space, and her job functions as an assistant attorney general. Citing to the regulations, the court noted that an accommodation is required to allow an employee with a disability to “enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities.”

The Court of Appeals affirmed summary judgment in favor of the employer on the employee’s retaliation claim because the employee failed to show the employer’s reasons for her termination were pretextual.

The Work Matters blog has a post on the decision here.

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