Employment Litigation · Primary-source case analysis

Barnett: A Seniority-System Exception Is Usually Not a Reasonable ADA Accommodation

By Aneeta Mishra and Timothy Chan

Published August 25, 2026

US Airways, Inc. v. Barnett involved an employee seeking to remain in a mailroom job as an accommodation after more senior employees became entitled to bid for it.

The employee first identifies a facially reasonable accommodation

Reassignment to a vacant position can be reasonable in the run of cases, but reasonableness must be evaluated against the employer’s established workplace rules.

A seniority system ordinarily controls

Because seniority systems create employee expectations and stable allocation rules, a conflicting exception is normally not reasonable without more.

Special circumstances can change the result

An employee may show frequent employer exceptions, retained unilateral discretion, or other facts demonstrating that one more departure would not materially undermine expectations.

The inquiry remains case specific

The holding does not automatically validate every asserted seniority practice or eliminate the duty to explore other effective accommodations.

Key takeaways

• Obtain the written seniority rules and bidding history.
• Identify prior exceptions and management discretion.
• Document alternative vacant positions and accommodations.
• Analyze undue hardship separately from facial reasonableness.