Second Circuit Expands ADA Protections: Reasonable Accommodations Not Just for Job Performance

This article is from The National Law Review: https://ow.ly/XaUu50Vx5UB In a significant decision with implications for employers across New York, Connecticut, and Vermont, the Second Circuit Court of Appeals has adopted a broad interpretation of the Americans with Disabilities Act (ADA). In its March 25, 2025 ruling in Tudor v. Whitehall Central School District, the court held that employees with disabilities may be entitled to reasonable accommodations even if they are able to perform their essential job functions without them.

This decision reinforces a growing national consensus that the ADA protects not only an employee’s ability to do the job, but also their ability to do it without unnecessary harm, stress, or disadvantage due to a disability.

The Case: PTSD, Denied Breaks, and a Lawsuit

The case involved Angel Tudor, a high school teacher in New York diagnosed with post-traumatic stress disorder (PTSD). Tudor requested brief afternoon breaks as a reasonable accommodation to manage her condition. Although she could technically fulfill her job responsibilities without the breaks, she testified that doing so caused her great duress and harm.

The school district denied her request, and a lower court dismissed her lawsuit, reasoning that because Tudor could perform her job's essential functions, she was not entitled to accommodation. The Second Circuit disagreed and reversed the dismissal.

The Ruling: Accommodations Are About More Than Just Performance

The Second Circuit clarified a key principle under the ADA:

A “qualified individual” under the ADA is someone who can perform the essential functions of the job with or without reasonable accommodation.

This means that the ability to perform a job without accommodation does not negate the right to receive one. In other words, if an accommodation would reduce the harm or stress caused by a disability—even if it doesn’t affect job performance—an employer must still consider it.

This interpretation aligns the Second Circuit with at least six other federal appellate courts, which have similarly ruled that workplace accommodations can support well-being and inclusion, not just basic job functionality.

Why This Matters for Employers

This ruling marks a pivotal shift in how employers must evaluate accommodation requests. Key takeaways include:

• Reasonable accommodations may be required even if the employee can “get the job done” without them.

• The focus is not just on whether an employee can perform, but how they are affected while doing so.

• Employers should avoid dismissing requests simply because the employee has managed without the accommodation in the past.

• The ruling emphasizes the ADA’s goal of supporting inclusion, equity, and sustainability in the workplace—not just bare-bones compliance.

  
  

What Employers Should Do Now

In light of the Tudor decision, employers—especially those in the Second Circuit—should:

1. Review and update reasonable accommodation policies to reflect the ADA’s broad scope.

2. Train HR professionals and managers to evaluate accommodation requests based on impact to the employee, not just job performance.

3. Engage in a meaningful interactive process when an accommodation request is made, even if the employee is currently performing well.

4. Consult with legal counsel when denying accommodation requests to ensure the decision is ADA-compliant.

   
   

Final Thoughts

The Second Circuit’s decision in Tudor v. Whitehall Central School District reinforces that the ADA protects not just productivity, but dignity, inclusion, and well-being. Employers must move beyond a narrow view of accommodations and adopt a more holistic, employee-centered approach to disability inclusion.