Beth Lyons v. The Legal Aid Society
1995 U.S. App. LEXIS 31019, 68 F.3d 1512, 4 Am. Disabilities Cas. (BNA) 1694 (1995)
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Rule of Law:
An employer's duty under federal disability statutes to provide a reasonable accommodation may extend to measures that enable a qualified employee with a disability to get to and from the workplace. The determination of whether a requested accommodation, such as a provided parking space, is reasonable is a fact-specific inquiry that generally cannot be resolved on a motion to dismiss.
Facts:
- Beth Lyons, an attorney for the Legal Aid Society in Manhattan, was struck by a car in 1989, resulting in severe and permanent injuries that significantly limited her ability to walk long distances, stand, or use stairs.
- After a multi-year disability leave, Lyons was medically cleared to return to work in 1993, though she still required walking devices.
- Due to her physical limitations, Lyons could not commute from her home in New Jersey to her Manhattan office via public transportation.
- Before returning to work, Lyons asked Legal Aid to accommodate her disability by paying for a parking space near her office, providing a letter from her physician stating this was necessary for her to return to work.
- Legal Aid refused Lyons's request for a paid parking space.
- Consequently, upon her return to work, Lyons had to pay between $300 and $520 per month for a parking space herself, which constituted a significant portion of her net salary.
Procedural Posture:
- Beth Lyons filed a complaint against the Legal Aid Society in the U.S. District Court for the Southern District of New York, alleging violations of the ADA and Rehabilitation Act.
- Legal Aid moved to dismiss the complaint for failure to state a claim upon which relief can be granted, pursuant to Federal Rule of Civil Procedure 12(b)(6).
- The district court granted Legal Aid's motion, dismissing Lyons's federal claims and declining jurisdiction over her state-law claims.
- Lyons, as the appellant, appealed the dismissal to the U.S. Court of Appeals for the Second Circuit; Legal Aid is the appellee.
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Issue:
Does an employee's request for an employer-provided parking space near the workplace, as an accommodation for a disability that limits her ability to use public transportation, fail as a matter of law to state a claim for a 'reasonable accommodation' under the Americans with Disabilities Act and the Rehabilitation Act?
Opinions:
Majority - Kearse, Circuit Judge
No. A request for an employer-provided parking space does not fail as a matter of law to state a claim for a reasonable accommodation under the ADA and the Rehabilitation Act. The complaint alleges sufficient facts to state a claim for discrimination based on a failure to accommodate, and the reasonableness of the requested accommodation is a fact-intensive question that is inappropriate for resolution on a motion to dismiss. The court reasoned that an employer's obligation to provide a reasonable accommodation is not limited to the physical workspace but can include measures that enable an employee to perform the essential functions of the job, which includes getting to the job site. Citing EEOC guidance that lists 'providing reserved parking spaces' as a potential accommodation, the court found nothing inherently unreasonable in requiring an employer to assist an employee in getting to work. The determination of reasonableness requires a case-by-case analysis involving a 'common-sense balancing of the costs and benefits,' which necessitates the development of a factual record regarding the employer's resources and the specific circumstances.
Analysis:
This decision clarifies that the scope of 'reasonable accommodation' under the ADA and Rehabilitation Act is not confined to the immediate work environment but can encompass accommodations necessary for an employee to commute to work. It establishes that a request for a parking space cannot be summarily dismissed as a demand for a personal convenience or fringe benefit. This precedent makes it more difficult for employers to obtain early dismissal of failure-to-accommodate claims related to commuting, forcing a more thorough, fact-based inquiry into the reasonableness of such requests and the potential for undue hardship.
