Borkowski v. Valley Central School District’s Empirical Analysis
63 F.3d 131 · 1995
Citation profile
69 federal appellate · 25 district · 12 state decisions
How this case has been cited
Cited by 233 later decisions (1 by the Supreme Court) — most recently March 2025 · most notably US Airways, Inc. v. Barnett (2002), D'Amico v. City of New York (1998)
69 federal appellate · 25 district · 12 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 29 U.S.C. § 701 (Employment Opportunities for Individuals With Disabilities Act) · 29 U.S.C. § 791 · 29 U.S.C. § 794 · 42 U.S.C. § 12101 (§ 2 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12111 (§ 101 of the Americans with Disabilities Act of 1990) · 42 U.S.C. § 12112 (§ 102 of the Americans with Disabilities Act of 1990)
Relies on Southeastern Community College v. Davis · Cities of Charlottesville v. Official Committee of Unsecured Creditors of Columbia Gas Transmission Corp. · School Board of Nassau County Florida v. H Arline · Alexander v. Choate · Gallo v. Prudential Residential Services, Ltd. Partnership
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 233 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[o]nce the plaintiff has done this, she has made out a prima facie showing that a reasonable accommodation is available, and the risk of nonpersuasion falls on the defendant.”
29 later decisions quote this exact passage · from the majority“[o]n the issue of reasonable accommodation, the plaintiff bears only the burden of identifying an accommodation, the costs of which, facially, do not clearly exceed its benefits.”
6 later decisions quote this exact passage · from the majority“(1) In general. Undue hardship means, with respect to the provision of an accommodation, significant difficulty or expense incurred , by a covered entity, when considered in light of the factors set forth in paragraph (p)(2) of this section. (2) Factors to be considered. In determining whether an accommodation would impose an undue hardship on a covered entity, factors to be considered include: (i) The nature and net cost of the accommodation needed under this part, taking into consideration the availability of tax credits and deductions, and/or outside funding; (ii) The overall financial resources of the facility or facilities involved in the provision of the reasonable accommodation, the number of persons employed at such facility, and the effect on expenses and resources; (iii) The overall financial resources of the covered entity, the overall size of the business of the covered entity with respect to the number of its employees, and the number, type and location of its facilities; (iv) The type of operation or operations of the covered entity, including the composition, structure and functions of the workforce of such entity, and the geographic separateness and administrative or fiscal relationship of the facility or facilities in question to the covered entity; and (v) The impact of the accommodation upon the operation of the facility, including the impact on the ability of other employees to perform their duties and the impact on the facility’s ability to conduct busine”
5 later decisions quote this exact passage · from the concurrence
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.