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ADA Reasonable Accommodation Analysis Memo Prompt

Analyzing ADA reasonable accommodation requests for employers or employees. The interactive process and documentation are critical to both granting accommodations and defending denials.

📋 Prompt — Copy & Use
You are an employment attorney analyzing an Americans with Disabilities Act (ADA) reasonable accommodation request. Draft an analysis memo for the following situation:

**Employee:** [Job title and essential functions of the position]
**Employer:** [Company size — ADA applies to employers with 15+ employees]
**State:** [State — some states have stricter disability laws, e.g., California FEHA]
**Disability/Medical Condition:** [General description — avoid specific diagnosis if possible]
**Functional Limitations:** [How does the condition limit the employee's major life activities or work functions?]
**Accommodation Requested:**
[What specifically did the employee request? Leave extension, remote work, modified schedule, equipment, reassignment, etc.]
**Medical Documentation Provided:** [What documentation has the employee provided?]
**Interactive Process Status:** [Has the employer engaged in the interactive process? What has been discussed?]
**Business Concerns:**
[Describe any hardship concerns: operational impact, cost, safety, effect on other employees]

Analyze:

**1. ADA COVERAGE** — Does the employee have a "disability" under the ADA? (Broad post-ADAAA definition)
**2. QUALIFIED INDIVIDUAL** — Can the employee perform the essential functions with or without accommodation?
**3. REASONABLE ACCOMMODATION DUTY**
- Is the requested accommodation reasonable on its face?
- What alternative accommodations should be considered?
- Is there an obligation to reassign to a vacant position?
**4. UNDUE HARDSHIP ANALYSIS**
- Factors: cost, employer size, nature of business, impact on operations
- What evidence is needed to support an undue hardship defense?
**5. INTERACTIVE PROCESS**
- Has the employer met its interactive process obligations?
- What additional steps are required?
**6. RECOMMENDATION**
- Grant / Modify / Deny the accommodation with supporting rationale
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✓ Best Practices

  • Engage in the interactive process promptly — delays in responding to accommodation requests are themselves ADA violations
  • Request only medical documentation that is relevant to the functional limitations — not the diagnosis
  • Consider all possible accommodations before denying — the ADA requires genuine engagement
  • California FEHA has a lower undue hardship threshold and broader disability definition than ADA
  • Document every step of the interactive process — documentation is your defense

⚠ Limitations

  • ADA accommodation analysis is highly fact-specific — results depend on the exact job functions and limitations
  • Essential function determination requires careful analysis of job description vs. actual job duties
  • Leave as accommodation is an evolving area — EEOC guidance should be reviewed for current standards

Expected Output

A complete ADA accommodation analysis memo with coverage, qualified individual, reasonable accommodation, undue hardship, and interactive process analysis. Approximately 1,200–2,000 words.

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Important: AI-generated legal content requires review by a licensed attorney before reliance. Verify all cited cases and legal authority independently. Nothing on this page constitutes legal advice.