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The U.S. Court of Appeals for the Eleventh Circuit, in Beasley v. O’Reilly Auto Parts, recently held that a claim for failure-to-accommodate under the Americans with Disability Act (ADA) must include an adverse employment action. That is, “discrimination in the form of a failure to reasonably accommodate is actionable under the ADA only if that failure negatively impacts the employee’s hiring, advancement, discharge, compensation, training, and other terms, conditions, and privileges of his employment.
