Last week, the United States Court of Appeals for the 10th Circuit, which encompasses Oklahoma, held that a plaintiff is not required to show that she suffered an adverse employment action in order to assert a failure to accommodate claim under the Americans with Disabilities Act (ADA). In Exby-Stolley v. Board of County Commissioners, Weld County Colorado, the 10th Circuit joined several other circuit courts of appeal that have held an adverse employment action is not a prerequisite to such a claim. More.