Noll v. Int'l Bus. Mach. Corp., No. 13-4096 (2d Cir. 2015)
Annotate this CasePlaintiff, a software engineer, filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12112, and the New York State Human Rights Law, N.Y. Exec. Law 296, against his employer for disability discrimination, alleging that the employer did not accommodate his deafness by arranging that all video files stored on its corporate intranet be captioned when posted and that all audio files be posted with transcripts. The court concluded that the employer provided plaintiff with reasonable accommodations by providing an American Sign Language interpreter. There is no evidence that the interpreters the employer provided were unqualified or that the use of interpreters was somehow inconsistent with plaintiff’s position as a software engineer. Plaintiff's objection - that he had to look back and forth between an interpreter and his screen - did not, without more, make that accommodation unreasonable. The court held that the ADA imposes no liability for an employer’s failure to explore alternative accommodations when the accommodations provided to the employee were plainly reasonable. In this case, because the employer provided reasonable accommodation to plaintiff, any failure to engage in an interactive process - even if supported by the record - did not give rise to a discrimination claim. Accordingly, the court affirmed the district court's grant of summary judgment to the employer.
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