Tudor v. Whitehall Central School District

What the court decided

An employee with a disability can be entitled to a reasonable accommodation under the ADA even if she can do the essential parts of her job without one. The statute defines a qualified person as one who can do the job "with or without reasonable accommodation," and the court held that "with or without" means with or without. It added that "[i]n at least some circumstances, the ADA requires an employer to offer accommodations that mitigate (if not necessarily eliminate) an employee's disability-related pain." The teacher, who has PTSD, had asked for two short off-campus breaks a day, which she had been given for years before a new administration stopped them.

Who won

The teacher won this round. The Second Circuit vacated summary judgment for the school district and sent the case back. The district may still argue that the breaks were unreasonable or an undue hardship.

Why it matters for workers with a medical condition

You do not have to prove you cannot work at all without the change you are asking for. If working without it means working in pain, that can be enough to require the employer to consider it.

Key passage: 132 F.4th at 246–48.

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.