Raymond v. 1199SEIU National Benefit Fund

What the court decided

An accommodation has to be effective. After a benefits-fund outreach worker with a serious vein condition was told by his doctor not to drive more than thirty minutes at a time, his employer removed the four farthest stops from his route but left others that were still far away, then fired him when he could not return "without restrictions." The court held that an employer's response, "even one that reduces the employee's workload or addresses some of the employee's needs, is not necessarily a reasonable accommodation." It also held that his request to go back to his old territory could be a plausible accommodation even though a colleague now covered it, if the employer regularly moved coordinators between areas, relying on the Supreme Court's reasoning in US Airways v. Barnett.

Who won

The worker won this round. The Second Circuit vacated summary judgment on his failure-to-accommodate claim and sent it back. His separate appeal from the jury verdict against him on his discrimination claim was dismissed because the court could not review it.

Why it matters for workers with a medical condition

An employer that does something is not automatically off the hook. The question is whether what it did actually lets you do the job within your medical limits.

Key passage: 184 F.4th at 54–57.

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.