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Stress-Free Workplace Not A
Reasonable Accommodation Under the ADA
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The Facts
The
Court’s Decision
Lesson
for Employers
An employer does not have to
provide a stress-free working environment as a reasonable
accommodation under the Americans with Disabilities Act ("ADA"), the
Third Circuit Court of Appeals ruled in Gaul v. Lucent
Technologies, No. 97-5114, 1/22/98. Upholding the district
court’s decision of summary judgment for Lucent Technologies
(formerly part of AT&T), the Third Circuit determined that the
employee failed to demonstrate that his request for a stress-free
workplace was a reasonable accommodation.
The Facts
Dennis Gaul worked as a technical associate for AT&T from 1981
to 1992. During this time, he was treated for depression and
anxiety-related disorders and took two disability leaves of absence.
Following the second leave, Gaul was assigned to work on development
of a new product. From the beginning of the new assignment, Gaul had
conflicts with his coworker, claiming the coworker refused to share
necessary information with him, unfairly used information from
Gaul’s database, and did not acknowledge Gaul’s contributions to the
project. Attempts to resolve the conflict with the coworker and
various supervisors were unsuccessful. Gaul requested a transfer to
a job where he would not be stressed by coworkers. Neither Gaul nor
his supervisor followed up on the transfer request, and two weeks
later in September 1992, Gaul took disability leave. Gaul filed suit
in 1994, alleging disability discrimination under the ADA because
AT&T did not accommodate him by transferring him to a position where
he would not be subjected to "prolonged and inordinate stress" by
coworkers. The district court granted AT&T’s motion for summary
judgment, and Gaul appealed.
The Court’s Decision
The Third Circuit affirmed the district court’s decision because
Gaul did not demonstrate that the benefits associated with the
proposed transfer would outweigh its costs. In its decision, the
court focused on the difficulty that AT&T would have in providing a
working environment without "prolonged and inordinate stress." The
court identified three factors for denying the accommodation: (1)
Gaul’s proposed accommodation would impose an impractical obligation
on the employer; (2) Gaul’s request would require the employer to
consider his stress level when assigning him to projects; and (3)
Gaul was asking the court to establish the conditions of his
employment with AT&T. Because the court determined that the
accommodations request was unreasonable, it declined to rule if the
employee was disabled under the ADA.
Lesson for Employers
This case is a favorable decision for employers since it
establishes that a stress-free workplace generally is not a
reasonable accommodation under the ADA. Under the ADA, employers
must provide reasonable accommodation so the employee can perform
the essential functions of the job. However, employers do not have
to provide the accommodation if it would create an unreasonable
burden.
In this decision, the court seemed reluctant to require the
employer to make an accommodation that would involve continual
monitoring and readjustment of a hard-to-define standard, i.e,
whether the employee was exposed to "prolonged and inordinate
stress." In addition, the court refused to usurp the employer’s
authority to assign employees by determining where the employee
should work within the organization.
For more information, contact the federal
Job Accommodation Network ("JAN") at 1-800-526-7234 or visit the web
site at http://www.jan.wvu.edu.
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This
article is not intended as legal advice. Readers are encouraged to seek
appropriate legal or other professional advice.
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