A requested disability accommodation does not have to be linked to the essential functions of the employee’s job. Feist v. State of Louisiana. 

An assistant attorney general in Louisiana suffered from osteoarthritis in her knee. She requested a free on-site parking space as an accommodation of her disability.  Her employer, the Louisiana’s Department of Justice, refused the request. She filed a Charge of Discrimination with the EEOC. As she continued working thereafter, she made a couple of major litigation mistakes including a failure to timely oppose a motion for summary judgment. The mistake resulted in a judgment against Louisiana. She was then terminated. A lawsuit ensued for failure to accommodate and retaliation.

Employers are obligated to make reasonable accommodations for the “known physical or mental limitations of an otherwise qualified individual with a disability” unless undue hardship can be established by the employer. Required accommodations may include, among other things, making the physical facility “readily accessible to and useable” by disabled employees. The language of the ADA does not suggest that an accommodation must be directly connected to the essential functions of an employee’s job. The request of a parking space fits within the definition of an accommodation, as it would have made the place readily accessible and useable. The district court’s finding to the contrary was reversed and remanded to district court. Her retaliation claim was dismissed as Louisiana had a legitimate business reason for her termination.