Pulcino v. Fed. Express Corp

In Pulcino v. Fed. Express Corp., 141 Wn.2d 629, 641, 9 P.3d 787 (2000), the Court found the commission's definition "unworkable" in the context of analyzing reasonable accommodation claims and were forced to employ an alternative definition of "disability," requiring that an allegedly disabled plaintiff establish only "that: (1) he or she has/had a sensory, mental, or physical abnormality and; (2) such abnormality has/had a substantially limiting effect upon the individual's ability to perform his or her job." To establish a prima facie case of failure to reasonably accommodate a disability under our case law, a plaintiff must show that: (1) the employee had a sensory, mental, or physical abnormality that substantially limited his or her ability to perform the job; (2) the employee was qualified to perform the essential functions of the job in question; (3) the employee gave the employer notice of the abnormality and its accompanying substantial limitations; (4) upon notice, the employer failed to affirmatively adopt measures that were available to the employer and medically necessary to accommodate the abnormality. See Pulcino, 141 Wn.2d at 643.