ADA accommodations do not have to relate to essential job functions

The Fifth Circuit has clarified an important Disabilities Act issue in a case vacating summary judgment against an employee. Feist v. Louisiana, CA No. 12-31065 (9/16/13). The district court held the employee failed to establish a nexus between the requested accommodation and any essential function of her job. In the district court's view that was fatal to her claim she was denied a reasonable accommodation. In vacating and remanding, the Fifth Circuit panel (Davis, Jones, Benavidies) relied upon the statute and DoL regulations to conclude a request for a "free on-site parking space" to accommodate her osteoarthritis of the knee could be a reasonable accommodation because it could make existing facilities readily accessible. The case was remanded to determine whether the request was reasonable.