In Noll v. IBM,1 the U.S. Court of Appeals for the Second Circuit held that the Americans with Disabilities Act (ADA) does not impose liability for an employer’s failure to explore alternative accommodations for an employee’s disability where the accommodations provided to the employee were “plainly reasonable.” The Noll decision was significant in that it addressed the limitations of an employer’s requirement to provide an accommodation when dealing with employees with a disability.
Under Noll, while an accommodation must be “reasonable and effective,” it need not be one that is perfect or the one that is most preferred by the employee. This article briefly discusses the background of the ADA as it relates to the issue of providing “reasonable accommodations,” analyzes the Noll decision, and concludes with a discussion of how Noll has been subsequently applied in recent court decisions.
