Use of AI Tools as a Reasonable Accommodation?

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To date, the conversation surrounding artificial intelligence tools in the workplace has mostly focused on an employer’s use of AI in the decision-making process and related risks and guidance. Given the privacy and security concerns inherent in the use of AI, many employers have also implemented AI policies that prohibit or significantly limit an employee’s ability to use AI tools for work-related tasks. However, Cedeno v. Walt Disney World Parks and Resorts, currently pending in the United States District Court for the Middle District of Florida, marks a shift in this conversation and raises familiar ADA principles in a novel context: if, when, and how AI tools may constitute a reasonable accommodation under the ADA.

On October 23, 2025, Angeliz E. Bruno Cedeno filed suit against Walt Disney World Parks and Resorts, alleging disability discrimination. Cedeno suffered from postpartum eye impairments, including light sensitivity and astigmatism. Her physician prescribed Meta smart glasses to assist with these conditions. Cedeno worked as a security host at Disney World and wore the Meta glasses to work for some time until her manager discovered they were not regular eyeglasses. When she learned Disney World would likely prohibit her use of the smart glasses, Cedeno filed a formal ADA accommodation request and medical certification from her physician. Disney World ultimately banned the use of smart glasses for all employees, thereby denying Cedeno’s accommodation request.

Cedeno is in the early stages, but it has garnered attention because it lies at the crossroads of disability rights, modern technology, and an employer’s obligation to engage in a fact-specific, individualized interactive process. The Cedeno decision should provide clarity on if and when an AI-powered tool constitutes a reasonable accommodation and how employers should reconcile their ADA obligations with legitimate business and privacy concerns.

Cedeno is the first lawsuit on this issue, but it likely will not be the last. On the one hand, employers’ AI policies are only growing more stringent, and on the other, AI’s capabilities are rapidly advancing and could conceivably be used to address a wide array of ADA-qualifying disabilities. This tension, coupled with little guidance on the issue, creates fertile ground for future lawsuits like Cedeno. Until we receive further guidance, employers should anticipate an uptick in AI-related accommodation requests and respond to such requests as they would any other. 

The appropriate response begins with timely initiating and engaging in the interactive process with the employee. If the employee requests a specific accommodation, the employer should evaluate it for reasonableness, including: (1) whether the AI tool will allow the employee to perform the essential functions of the role without eliminating or materially altering the function; (2) assessing the security, confidentiality, privacy, and compliance risks associated with use of the AI tool and any methods to mitigate these risks; and (3) considering the cost and feasibility of using the tool, including any training required for effective use. If the requested accommodation poses an undue hardship on the employer, it should identify effective alternatives that would allow the employee to perform the essential functions of the job. However, if the employer determines use of the AI tool is reasonable, it should grant the accommodation request and, in doing so, set clear performance and usage expectations that strike the balance of effective use and protecting the employer’s legitimate business interests and security concerns.

Maynard Nexsen’s Employment & Labor group is actively monitoring the Cedeno case for further guidance on this issue and any subsequent takeaways for employers.