In Cuiellette v. City of Los Angeles (2011) 194 Cal.App.4th 757, a court trial resulted in a judgment in favor of the plaintiff, a disabled officer in the Los Angeles Police Department (LAPD), on his FEHA claims. On appeal, the defendant contended the judgment was not supported by substantial evidence because the evidence showed the plaintiff was unable to perform the essential functions of a police officer, such as making a forcible arrest, with or without reasonable accommodation. (Cuiellette, supra, 194 Cal.App.4th at pp. 760, 768.) The plaintiff in Cuiellette was restricted by his doctor to administrative work. (Id. at p. 761.) The Second District affirmed, reasoning that, even if the plaintiff "could not perform all of the essential functions of a police officer, he could perform the essential functions of" an administrative position into which he briefly had been placed as an accommodation. (Id. at p. 760.) Critically, the trial court had found that, during the relevant time period, " 'the City of Los Angeles had a longstanding policy and practice of allowing sworn officers to perform "light duty" assignments that did not entail several essential functions of a peace officer such as making arrests, taking suspects into custody, and driving a police vehicle in emergency situations.' " (Id. at p. 762.) Since the LAPD maintained such light-duty positions for disabled officers, the essential functions of those positions were not the same as the essential functions of a police officer in the field. Thus, Cuiellette, explained, "because the LAPD maintained permanent, light-duty positions that it staffed with police officers who could not perform all of the essential duties of a police officer, the relevant inquiry is whether the plaintiff was able to perform the essential duties of the light-duty assignment he was given on his return to work and not whether he was able to perform all of the essential duties of a police officer in general." (Cuiellette, supra, 194 Cal.App.4th at p. 769.) Cuiellette supports the proposition that employers must provide accommodations into permanent light-duty assignments if such assignments exist; Cuiellette does not support the proposition that employers are required to create permanent light-duty assignments to accommodate disabled employees.