context: As a result, all that remains of either part of Marks's claim is a theory that the Company's delay in granting his requests denied him a reasonable accommodation. To be sure, an employer's "unreasonable" delay may constitute the denial of an accommodation in some circumstances.
citation_a.signal: see also
citation_a.identifier: 613 F.3d 1162, 1168
citation_a.parenthetical: suggesting there are situations where "a long-delayed accommodation" could be considered "unreasonable" and hence "actionable under the ADA"
citation_a.sentence: Valle-Arce v. Puerto Rico Ports Auth., 651 F.3d 190, 200 (1st Cir. 2011); Astralis Condo. Ass’n v. Sec’y, U.S. Dep’t of Hous. & Urban Dev., 620 F.3d 62, 68-69 (1st Cir. 2010) (holding condominium association’s delay of more than a year in deciding on request for designated handicapped parking spaces constituted a denial of accommodation request); see also Mogenhan v. Napolitano, 613 F.3d 1162, 1168 (D.C. Cir. 2010) (suggesting there are situations where “a long-delayed accommodation” could be considered “unreasonable” and hence “actionable under the ADA”) (quoting Mayers v. Laborers’ Health & Safety Fund, 478 F.3d 364, 368 (D.C. Cir. 2007)).
citation_b.signal: no signal
citation_b.identifier: 620 F.3d 62, 68-69
citation_b.parenthetical: holding condominium association's delay of more than a year in deciding on request for designated handicapped parking spaces constituted a denial of accommodation request
citation_b.sentence: Valle-Arce v. Puerto Rico Ports Auth., 651 F.3d 190, 200 (1st Cir. 2011); Astralis Condo. Ass’n v. Sec’y, U.S. Dep’t of Hous. & Urban Dev., 620 F.3d 62, 68-69 (1st Cir. 2010) (holding condominium association’s delay of more than a year in deciding on request for designated handicapped parking spaces constituted a denial of accommodation request); see also Mogenhan v. Napolitano, 613 F.3d 1162, 1168 (D.C. Cir. 2010) (suggesting there are situations where “a long-delayed accommodation” could be considered “unreasonable” and hence “actionable under the ADA”) (quoting Mayers v. Laborers’ Health & Safety Fund, 478 F.3d 364, 368 (D.C. Cir. 2007)).