The following excerpt is from Borkowski v. Valley Cent. School Dist., 63 F.3d 131 (2nd Cir. 1995):
The District of Columbia Circuit takes a very different approach. That Circuit distinguishes between the tests for a "reasonable accommodation" and an "undue hardship." See Barth v. Gelb, 2 F.3d 1180 (D.C.Cir.1993),
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