As employers know, the Americans with Disabilities Act (ADA) requires employers to provide “reasonable accommodation” to employees with disabilities to enable them to perform the essential function of their jobs.  What employees demand as a “reasonable accommodation” under the Americans with Disabilities Act, however, may not always be so reasonable.  Fortunately, courts are generally more rational than employees in assessing how “reasonable” an accommodation is.

For example, in the recent federal case, Tomlinson v. Wiggins, an employee who had been diagnosed with depression complained to Human Resources about his supervisor’s management style.  He was subsequently terminated for performance reasons and he sued his employer, asserting an ADA claim for failure to reasonably accommodate his disability, among other things.  Specifically, the employee claimed that his complaint to HR about his supervisor’s management style was a request for accommodation.  The Court found, however, that this so-called accommodation request was essentially a demand for a stress-free environment.  Noting that the law does not require an employer to provide “an aggravation-free environment,” the Court determined that the accommodation was not reasonable and the employer had no duty to provide it.

Workplace stress is normal.  It’s reassuring that courts understand that, and will not set employers the impossible task of providing a stress-free workplace.