When Reasonable Accommodation Is Requested, The Interactive Process Begins

The U.S. Equal Employment Opportunity Commission (EEOC) sued American Airlines, Inc., a domestic and international air carrier headquartered in Texas, for alleged violations of the Americans with Disabilities Act. American Airlines will pay $200,000 to settle the lawsuit.

According to the EEOC's allegations, a Fort Worth-based employee, who developed cortical blindness, requested, as a reasonable accommodation, screen reader software to convert text and other information on computers into synthesized speech. In lieu of that software, the employee requested a transfer to another position.

The EEOC alleged American failed to engage in an interactive process to discuss reasonable accommodations and instead put the employee on unpaid, involuntary leave for nearly four years, after which time American fired the employee. 

The lawsuit (U.S. EEOC v. American Airlines, Inc., Case No. 4:25-cv-01056-P) was filed in the U.S. District Court for the Northern District of Texas, Fort Worth Division, after failed attempts to reach a pre-litigation settlement through the EEOC's administrative conciliation process.

In addition to paying $200,000 in monetary relief, under a two-year consent decree resolving this lawsuit, American Airlines will integrate the Web Content Accessibility Guidelines into its development of new, accessible reservation software the company is projected to launch in 2027. Once that is implemented, American Airlines is required to conduct an accessibility audit of the software by a trained specialist and dedicate up to 120 hours of labor to remedy any barriers to accessibility for blind and visually-impaired employee-users that may still exist.

In addition, American Airlines will also train its human resource employees with job duties that include responding to reasonable accommodation requests; post an employee notice about disability discrimination; and provide reports to the EEOC about relevant employee accommodation requests.

"American Airlines to Pay $200,000 in EEOC Disability Discrimination Suit Following Termination of Blind Employee" eeoc.gov (Aug. 28, 2026).

Commentary

When a request for a reasonable accommodation is made, an employer must engage in an interactive process to determine reasonable accommodations. The failure to engage itself can lead to a charge of disability discrimination.

Reasonable accommodations are made on a case-by-case basis, depending upon the job duties of the employee and the way in which the particular disability impairs or affects them.

In the above case, an employee developed a visual disability. The use of screen reader software may have allowed the employee to perform the job.

It is unlikely that the cost of such software would have been an "undue burden" for an employer the size of American Airlines under the ADA. Such a burden is defined as an action requiring significant difficulty or expense when considered in light of a number of factors. These factors include the nature and cost of the accommodation in relation to the size, resources, nature, and structure of the employer's operation. This termination is also made on a case-by-case basis.

There may have been other reasonable accommodations that would have allowed the employee to perform the job, but because American failed to engage in an interactive process with the employee, none were discovered or considered. 

There are numerous technical resources available to aid employers in their search for reasonable accommodations, including government rehabilitation agencies, nonprofit organizations, technology consultants, and the Job Accommodation Network, in addition to requesting suggested accommodations from the employee's healthcare provider.

The final takeaway is that whenever a request for a reasonable accommodation is made, an employer must engage in an interactive process.

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