And Exactly How Does Your Own Shredder Help You Perform Your Essential Job Functions?


Reinforcing a perhaps obvious point, the U.S. Court of Appeals for the Seventh Circuit recently reiterated that, under the Americans with Disabilities Act, the employer need provide only accommodations that are necessary to enable the employee to perform their essential job functions.

In Williams v. Board of Education of the City of Chicago, the employee was a social worker for the school system, suffering from depression, anxiety and chronic sinusitis. These conditions made it difficult for him to sleep at night, which consequently made it difficult for him to concentrate and recall information. He made a number of demands for accommodation, including that each of his assigned schools provide him with a private office and dedicated equipment, specifically: a telephone, a high‐capacity laser printer with extra ink, a private fax machine, a large high-resolution monitor, a high‐capacity shredder, a high-capacity scanner, a proper desk and swivel chair, and large HEPA filter. The schools gave him computer monitors and HEPA filters, and arranged for a private space to meet with students; his other equipment requests were denied. He subsequently sued, alleging a failure to accommodate these requests as well as others.

The Seventh Circuit summarily dealt with this claim, noting that the employee had not established how the requested equipment would help him accomplish the essential functions of his job. In a slightly snarky manner, the Seventh Circuit observed, “Moreover, despite his claim that he could easily explain the necessity for these specific requests, he has yet to set forth a connection between, for instance, his own dedicated shredder and his disability.”