Why Your Employee’s ADA Claim Might Succeed—Even If They Don’t Require Help

A recent Second Circuit decision underscores a critical point under the Americans with Disabilities Act (ADA) that employers often overlook: an employee who can perform the essential functions of their job without an accommodation may still have a viable failure-to-accommodate claim.

The case involved a teacher with PTSD who sued her employer after it stopped honoring a long-standing accommodation that allowed her to take short breaks off-campus during prep periods. Even though she managed to perform her duties without the breaks—albeit under significant psychological strain—the appellate court ruled that her claim could proceed.

The district court had previously granted summary judgment for the employer, reasoning that because the teacher admitted she could perform her job functions without the accommodation, she wasn’t entitled to one. But the Second Circuit vacated that decision, citing the ADA’s plain language: a “qualified individual” is someone who can perform essential job functions with or without a reasonable accommodation. The court explained that while the ability to do the job is relevant, it is not dispositive. A reasonable accommodation doesn’t have to be essential to job performance—it only has to be reasonable and aimed at mitigating disability-related limitations.

As the court put it: “An employee with a disability is qualified to receive a reasonable accommodation under the ADA even if she can perform the essential job functions without one.” The Second Circuit joined every other circuit to consider the issue, reinforcing a broad consensus that an employee’s ability to push through without accommodation does not foreclose their right to one.

Takeaways for Employers

1. Don’t Overlook the “With or Without” Language.
If your instinct is to deny an accommodation request because the employee can “get the job done” without it, take a step back. The question isn’t whether the employee needs the accommodation to survive the workday—it’s whether the accommodation would reasonably accommodate the employee without imposing undue hardship on the business.

2. Reasonableness Is a Fact-Intensive Inquiry.
The decision reinforces that there’s no bright-line rule here. Whether an accommodation is reasonable must be determined on a case-by-case basis, factoring in the nature of the job, the specific limitations of the employee, and the workplace context.

3. Engage, Don’t Dismiss.
Employers should not dismiss accommodation requests out of hand just because the employee is “managing.” Engage in the interactive process in good faith, explore options, and document every step. This approach isn’t just safer legally—it’s also better for morale and retention.

Above All: Be Practical

Assisting employees who ask for help—even when they can technically push through without it—is not just a compliance exercise. It’s smart management. A modest accommodation might make a significant difference in an employee’s well-being, productivity, and loyalty. And as long as the accommodation doesn’t cause undue hardship, the cost of saying “yes” is often far less than the cost of a lawsuit—or of losing a valuable employee. Helping employees manage their disabilities isn’t just the law. It’s good business.