April Tip of the Month: Second Circuit Opines on Reasonable Accommodation Issue

On March 25, 2025, the U.S. Court of Appeals for the Second Circuit clarified and potentially broadened the scope of an employer’s responsibility to offer reasonable accommodations under the Americans with Disabilities Act (ADA). 

Specifically, in Tudor v. Whitehall Central School District, the Second Circuit held that an employee may be entitled to a reasonable accommodation under the ADA even if the employee can perform the essential functions of their job without the accommodation. The court explained that, while the necessity of a requested accommodation may still be relevant, it is not dispositive. Employers must take this holding into account when assessing future accommodation requests.