context: For two years, he had not had the capacity to handle a product his company was marketing. When an employee requests an accommodation for the first time only after it becomes clear that an adverse employment action is imminent, such a request can be "too little, too late."
citation_a.signal: see also
citation_a.identifier: 110 Fed. Appx. 136, 138
citation_a.parenthetical: finding that plaintiffs presentation of therapist's letter requesting leave of absence after plaintiff threatened supervisor with violence was "untimely" as well as unreasonable
citation_a.sentence: Reed, 244 F.3d at 262 n. 9; see also Rose v. Laskey, 110 Fed. Appx. 136, 138 (1st Cir.2004) (per curiam) (finding that plaintiffs presentation of therapist’s letter requesting leave of absence after plaintiff threatened supervisor with violence was “untimely” as well as unreasonable); Hill v. Kan. City Area Transp. Auth., 181 F.3d 891, 894 (8th Cir.1999) (finding accommodation request untimely when employee made request only after committing two rule violations that “she knew would mandate her discharge”); Soileau v. Guilford of Me., Inc., 105 F.3d 12, 17 n. 4 (1st Cir.1997) (noting, in context of ADA retaliation claim, the “danger” of “permit[ting] an employee already on notice of performance problems to seek shelter in a belated claim of disability”); cf. Halpern v. Wake Forest Univ. Health Scis., 669 F.3d 454, 465 (4th Cir.2012) (rejecting medical student’s claim that school failed to reasonably accommodate his mental illness, in part because student did not allege that his behavioral problems were “manifestations of a disability” until after disciplinary board had recommended his dismissal); Wynne v. Tufts Univ. Sch. of Med., 976 F.2d 791, 796 & n. 3 (1st Cir.1992) (rejecting medical student’s claim that school failed to reasonably accommodate his learning disability, in part because student never requested alternative testing method until he had failed exam three times and faced expulsion).
citation_b.signal: cf.
citation_b.identifier: 669 F.3d 454, 465
citation_b.parenthetical: rejecting medical student's claim that school failed to reasonably accommodate his mental illness, in part because student did not allege that his behavioral problems were "manifestations of a disability" until after disciplinary board had recommended his dismissal
citation_b.sentence: Reed, 244 F.3d at 262 n. 9; see also Rose v. Laskey, 110 Fed. Appx. 136, 138 (1st Cir.2004) (per curiam) (finding that plaintiffs presentation of therapist’s letter requesting leave of absence after plaintiff threatened supervisor with violence was “untimely” as well as unreasonable); Hill v. Kan. City Area Transp. Auth., 181 F.3d 891, 894 (8th Cir.1999) (finding accommodation request untimely when employee made request only after committing two rule violations that “she knew would mandate her discharge”); Soileau v. Guilford of Me., Inc., 105 F.3d 12, 17 n. 4 (1st Cir.1997) (noting, in context of ADA retaliation claim, the “danger” of “permit[ting] an employee already on notice of performance problems to seek shelter in a belated claim of disability”); cf. Halpern v. Wake Forest Univ. Health Scis., 669 F.3d 454, 465 (4th Cir.2012) (rejecting medical student’s claim that school failed to reasonably accommodate his mental illness, in part because student did not allege that his behavioral problems were “manifestations of a disability” until after disciplinary board had recommended his dismissal); Wynne v. Tufts Univ. Sch. of Med., 976 F.2d 791, 796 & n. 3 (1st Cir.1992) (rejecting medical student’s claim that school failed to reasonably accommodate his learning disability, in part because student never requested alternative testing method until he had failed exam three times and faced expulsion).