Unreasonable Delays in Facilitating Reasonable Accommodation

Unreasonable Delays in Facilitating Reasonable Accommodation

Unreasonable Delays in Facilitating Reasonable Accommodations May Impose ADA Liability: A Legal Update on the Widespread Problem of Unreasonably Delayed Accommodations in Employment, Education, Public Entity, and Public Accommodations

When
May 20, 20261:00pm to 2:30pm
Eastern Time
Cost
Free
Where
Virtual
Format
Live event
Category
Employment
Region
Region 5 – Great Lakes ADA Center

In 2025 the United States Court of Appeals for the Fifth Circuit revived an Americans with Disabilities Act (ADA) failure-to-accommodate claim brought by an Army veteran whose employer delayed granting her request to bring a service dog to work. The court concluded that a six-month delay in providing the requested accommodation could itself constitute a failure to accommodate if the delay was unjustified–reflecting a lack of good-faith participation in the ADA-required interactive process. EEOC backed this decision emphasizing that unreasonable delays in providing reasonable accommodations may violate the ADA when employers impose unnecessary procedural barriers or require excessive medical documentation. Many organizations maintain formal ADA accommodation procedures, yet employees may still encounter prolonged internal review processes that effectively delay resolution of a request or request to revise existing accommodations. We will review ADA timing obligations, court decisions, and administrative guidance to emphasize that Courts have increasingly stressed that bureaucratic or unreasonable delays do not exempt ADA compliance and may amount to actual ADA liability even in cases where the accommodation was eventually provided.

Event Details

Status
Open
Credit
ADA Coordinator Certificate, Attendance
Accommodations
Open or Closed Captions

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