## Facts

- Beth Lyons worked as a staff attorney for the Legal Aid Society beginning in 1987.
- In 1989, Lyons suffered near-fatal injuries in a car accident, resulting in long-term mobility impairments and years of disability leave with surgeries and physical therapy.
- After the accident, Lyons could walk only with assistive devices, wore a knee brace, could not stand for extended periods, and had difficulty using stairs.
- Lyons returned to work in June 1993 and allegedly performed her job duties successfully despite continuing limitations.
- Lyons’s physician prescribed exercise to maintain her ability to walk and indicated that nearby parking was necessary to enable her to work.
- Lyons requested that Legal Aid provide and pay for a parking space near her office and near courthouses where she appeared, asserting the request was a reasonable accommodation under the ADA and Rehabilitation Act.
- Legal Aid denied the parking request, and Lyons alleged she incurred significant parking costs herself.
- Lyons also sought full seniority credit for her disability leave; Legal Aid allegedly denied credit in part.

## Issues

1. Whether Lyons plausibly alleged she was a qualified individual with a disability entitled to reasonable accommodation under the ADA and the Rehabilitation Act.
2. Whether an employer’s refusal to provide and pay for nearby parking can constitute a failure to provide a reasonable accommodation.
3. Whether the reasonableness of the requested accommodation may be rejected as a matter of law at the Rule 12(b)(6) pleading stage.

## Decision

- The Second Circuit vacated the district court’s dismissal and remanded for further proceedings.
- The court held the complaint alleged sufficient facts to state claims under the ADA and Rehabilitation Act.
- The court held the reasonableness of the requested parking accommodation could not be resolved against Lyons on a Rule 12(b)(6) motion.

## Legal Principles

- Under the ADA and the Rehabilitation Act, an employer must provide reasonable accommodation to a qualified employee with a disability unless doing so would impose undue hardship.
- Whether a proposed accommodation is reasonable is commonly a fact-dependent question that should not be resolved on the pleadings where the complaint plausibly alleges entitlement to relief.
- Reasonable accommodation may include measures that allow a disabled employee to access the workplace and to enjoy equal benefits and privileges of employment.
- Employer-provided parking or transportation-related assistance may qualify as a reasonable accommodation, depending on facts such as the employee’s limitations, job requirements, feasibility, and cost.
- Undue hardship is ordinarily a fact issue requiring record development rather than dismissal at the pleading stage when the complaint plausibly alleges a reasonable accommodation.

## Conclusion

The Second Circuit held that a disabled employee plausibly stated ADA and Rehabilitation Act claims based on an employer’s refusal to provide nearby parking, and that the reasonableness of such an accommodation generally requires factual development rather than dismissal under Rule 12(b)(6).


Lyons v. Legal Aid Soc'y, 68 F.3d 1512 (2d Cir. 1995)