Feist v. Louisiana, Department of Justice, Office of the Attorney General
730 F.3d 450, 28 Am. Disabilities Cas. (BNA) 813, 2013 WL 5178846 (2013)
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Rule of Law:
Under the Americans with Disabilities Act (ADA), a requested accommodation can be 'reasonable' even if it is not directly related to the performance of an employee's essential job functions. An accommodation is also reasonable if it makes the workplace accessible or allows the employee to enjoy equal benefits and privileges of employment.
Facts:
- Pauline G. Feist worked as an assistant attorney general for the Louisiana Department of Justice (LDOJ).
- Feist has osteoarthritis of the knee, a physical disability that limits her ability to walk.
- Due to her disability, Feist requested a free, on-site parking space as an accommodation.
- LDOJ denied Feist's request for the on-site parking space.
- Feist filed discrimination charges against LDOJ with the U.S. Equal Employment Opportunity Commission (EEOC).
- Subsequently, LDOJ terminated Feist's employment, citing poor performance on two specific legal cases.
Procedural Posture:
- Pauline G. Feist sued the Louisiana Department of Justice (LDOJ) in federal district court.
- Feist's lawsuit included claims for disability discrimination (failure to accommodate) under the ADA and retaliation under the ADA and Title VII.
- The LDOJ filed a motion for summary judgment, asking the court to dismiss the case without a full trial.
- The district court granted summary judgment for LDOJ on both the discrimination and retaliation claims.
- Specifically on the discrimination claim, the district court ruled that Feist's request for parking was not a reasonable accommodation because she failed to show how it limited her ability to perform the essential functions of her job.
- Feist (appellant) appealed the district court's decision to the U.S. Court of Appeals for the Fifth Circuit, with LDOJ as the appellee.
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Issue:
Does a requested accommodation under the Americans with Disabilities Act (ADA) need to be directly linked to the performance of an employee's essential job functions to be considered a 'reasonable accommodation'?
Opinions:
Majority - Benavides, Circuit Judge
No. A requested accommodation under the ADA does not need to be linked to the essential functions of an employee's job to be considered reasonable. The plain text of the ADA and its implementing regulations indicate that reasonable accommodations are not restricted to modifications that solely enable the performance of essential job functions. The ADA's definition of reasonable accommodation includes making facilities 'readily accessible to and usable by individuals with disabilities.' Furthermore, EEOC regulations establish three distinct categories of reasonable accommodation: (1) adjustments to the application process, (2) modifications to the work environment that enable performance of essential functions, or (3) modifications that enable an employee to enjoy 'equal benefits and privileges of employment.' The district court erred by focusing only on the second category and requiring a nexus between the requested parking space and Feist's core job duties. Therefore, the lower court's grant of summary judgment on the discrimination claim was improper.
Analysis:
This decision significantly clarifies the scope of an employer's duty to provide reasonable accommodations under the ADA in the Fifth Circuit. By rejecting the requirement that an accommodation must facilitate an 'essential job function,' the court broadens the types of requests that may be considered reasonable. The ruling emphasizes that accommodations related to workplace accessibility and equal enjoyment of employment benefits, such as parking, are valid under the ADA. This precedent strengthens the position of employees seeking accommodations that remove barriers to getting to or navigating the workplace, even if those barriers do not impede the performance of their specific job tasks.
