What is the test for making a reasonable accommodation for a person with a learning disability?

MultiRegion, United States of America

The following excerpt is from Borkowski v. Valley Cent. School Dist., 63 F.3d 131 (2nd Cir. 1995):

Whether a proposed accommodation is reasonable, however, is another question. "Reasonable" is a relational term: it evaluates the desirability of a particular accommodation according to the consequences that the accommodation will produce. This requires an inquiry not only into the benefits of the accommodation but into its costs as well. See Vande Zande v. Wisconsin Dep't of Admin., 44 F.3d 538, 542 (7th Cir.1995). We would not, for example, require an employer to make a multi-million dollar modification for the benefit of a single individual with a disability, even if the proposed modification would allow that individual to perform the essential functions of a job that she sought. In spite of its effectiveness, the proposed modification would be unreasonable because of its excessive costs. In short, an accommodation is reasonable only if its costs are not clearly disproportionate to the benefits that it will produce. Id. at 542-43; cf. Barth, 2 F.3d at 1187 (an accommodation may be unreasonable if its costs are excessive). 3

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