Cangro v. New York City Department of Finance

What the court decided

A Finance Department employee with chronic lung disease asked to do his in-office days at a Staten Island office instead of Manhattan. The court held that three facts together plausibly alleged he could do his job with that accommodation: he had done the job from home for two years during the pandemic, he was still allowed to work from home two days a week, and his manager supported the request. A complaint does not have to plead evidence. The court also noted that City law claims must be analyzed separately from federal claims.

Who won

Split. The Second Circuit reinstated his ADA and City failure-to-accommodate claims, but affirmed dismissal of his ADA discrimination claim and denial of leave to add a retaliation claim.

Why it matters for workers with a medical condition

A track record of doing your job remotely, or with the arrangement you are asking for, is evidence that the arrangement works.

Key passage: 183 F.4th at 160–62.

We do not host a copy of this decision. The full text is available free from United States Court of Appeals for the Second Circuit (official slip opinion).

This page summarizes the decision in plain language.