Americans with Disabilities Act

Rodal v. Anesthesia Grp. of Onondaga, P.C., No. 03-7341 (2d Cir. May 24, 2004)

An anesthesiologist filed a lawsuit against his group demanding compensatory and punitive damages under federal and state law for disability discrimination for failing to accommodate his disability. The district court granted the group's motion for summary judgment, ruling that (1) the anesthesiologist's request to be excused from night and weekend duty was not a reasonable accommodation because such duties were essential functions of the position, and (2) granting the accommodation would be unduly harmful to other physicians in the group who would have to assume greater responsibility for night and weekend duty.

The United States Court of Appeals for the Second Circuit found that the evidence, when viewed in a light most favorable to the anesthesiologist, did not permit a court to conclude as a matter of law that (1) the anesthesiologist failed to seek any accommodation for his disability from the group; or (2) if he had sought an accommodation, it was unreasonable because it would have required relieving him from essential job functions; or (3) even if his requested accommodation was reasonable, it nevertheless imposed an undue burden on the group. Accordingly, the court reversed the district court's judgment in favor of the group and remanded the case back to the district court.