Not according to the Fifth Circuit in the recent case of Sapp v. Donoh0e. Sapp was a U.S. postal service supervisor. However, she had a hard time playing well with others. She frequently got into arguments with co-workers as well as subordinates. After being diagnosed with depression, anxiety and a panic disorder, she requested to work in isolation, away from both subordinates and supervisors. The postal service refused her request, precipitating a claim of failure to accommodate under the Rehabilitation Act (which mirrors the ADA in most respects).
The Fifth Circuit affirmed summary judgment for the postal service. The employer was entitled to its position that interacting with both superiors and subordinates was an essential job function. The court noted that Ms. Sapp offered no evidence of an available position that would meet her desired restrictions.
This last point is worthy of mention, as the court did not make a blanket rule. It did not rule out the possibility that an employee in Sapp’s position could make out a failure to accommodate claim, if the facts lined up just right (i.e., there was an available position for which she was qualified that would meet her request). Remember, these reasonable accommodation cases are intensely fact specific. It’s a mistake to count on hard and fast rules. But this case does suggest some instructive guidelines for employers, and reasonable ones at that.