Stress-Free Workplace Not A Reasonable Accommodation Under the ADA

The Facts                                       [Download Free Policies]

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.

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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.