The following excerpt is from Livingston v. Fred Meyer Stores Inc, D.C. No. 3:06-CV-01825-HA, No. 08-35597 (9th Cir. 2010):
We have recognized that an employer has a duty to accommodate an employee's limitations in getting to and from work. See Humphrey v. Memorial Hospitals Ass'n, 239 F.3d 1128, 1135 (9th Cir. 2001) (holding that employer had a duty to accommodate employee with obsessive compulsive disorder, which interfered with her ability to get to work on time, or at all, but did not affect her
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