48 N.Y.2d 708 (1979)
Under the Human Rights Law as it existed in 1979, an employer’s refusal to accommodate an employee’s disability was not unlawful discrimination if the disability prevented the employee from performing the essential functions of their job.
Summary
The New York City Department of Social Services (DSS) denied a special officer’s request for light duty after he was injured on the job. The State Division of Human Rights found this to be unlawful discrimination based on disability. The Court of Appeals reversed, holding that because the officer’s disability prevented him from performing his regular duties (which sometimes required physical force), the DSS was not required to accommodate him under the Human Rights Law as it was written at the time. The law only prohibited discrimination based on disabilities unrelated to job duties. The court emphasized that the statute’s definition of “disability” controlled, regardless of whether light duty assignments were given to others.
Facts
Thomas Cole was employed as a special officer by the New York City Department of Social Services. While on duty, Cole sustained an injury. As a result of his injury, Cole requested a light duty assignment from the DSS. Cole’s request was denied by the DSS, even though light duty assignments were sometimes given to other officers who were not disabled. The State Division of Human Rights determined that Cole was “disabled and could not perform his regular duties as a Special Officer” due to his injury.
Procedural History
The State Division of Human Rights ruled that the New York City Department of Social Services had unlawfully discriminated against Thomas Cole. The Department of Social Services then petitioned to annul the determination of the State Human Rights Appeal Board. Simultaneously, the Division of Human Rights filed a cross-petition seeking enforcement of its determination. The Appellate Division’s order was appealed to the New York Court of Appeals.
Issue(s)
Whether the New York City Department of Social Services violated the Human Rights Law by refusing to grant a light duty assignment to a special officer whose disability prevented him from performing the essential functions of his job, given that the Human Rights Law at the time defined “disability” as conditions unrelated to the ability to perform job duties.
Holding
No, because the Human Rights Law at the time defined “disability” as conditions unrelated to the ability to engage in the activities involved in the job or occupation sought; since the complainant’s disability prevented him from performing his duties as a special officer, the denial of light duty was not unlawful discrimination under the then-existing statute.
Court’s Reasoning
The Court of Appeals focused on the statutory definition of “disability” in the Human Rights Law at the time of the alleged discrimination. The statute (Executive Law, § 292, subd. 21) limited the term “disability” to “conditions which are unrelated to the ability to engage in the activities involved in the job or occupation” sought. Because Cole’s injury prevented him from performing his regular duties as a special officer, the court held that his situation fell outside the protection of the statute. The court stated, “That inability to meet the needs of the department should have ended the inquiry, for complainant’s disability was within the express limitation of the statutory definition.” The court distinguished the situation from cases where an employee could perform the essential job functions despite their disability. The court reasoned that the division was without authority when it predicated its decision of unlawful discrimination on a job-related disability. The court cited Matter of State Div. of Human Rights v Averill Park Cent. School Dist., 46 NY2d 950 to support its reasoning.