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self-study / Implicit bias and the promotion of bias-reducing strategies

Mar. 23, 2026

Workers on the spectrum and the quiet frontier of employee civil rights

Pawanpreet K. Dhaliwal

Founding Attorney
Dhaliwal Law

See more...

Neurodivergent workers include those with autism, attention deficit disorder (ADD), attention deficit hyperactivity disorder (ADHD), and they sit at the quiet frontier of workplace civil rights. These employees are frequently praised for creativity, pattern recognition or hyperfocus, even as they are penalized for traits that flow from the same neurotype: difficulty with unstructured communication, sensory overload, or timemanagement challenges in environments designed for neurotypical brains.

Civil rights advocates know that discrimination rarely announces itself outright. For neurodivergent workers, it appears in print as "fit" concerns, vague criticisms about "attitude," or rigid application of policies that could easily be adjusted without undue hardship. The law offers powerful tools, but only when attorneys help translate lived experience into legal theory that judges and juries can understand.

Understanding neurodiversity beyond the diagnosis

"Neurodiversity" is a term coined by Australian sociologist Judy Singer in 1998. While not a medical label, it has emerged as a civil rights and cultural framework: the idea that all brains, like bodies, are different. Furthermore, they exist along a spectrum of natural variation. Autism and ADHD are widely recognized as neurologically based differences that can affect communication, executive functioning, sensory processing and social interaction.

In practice, that means two workers with the same diagnosis may have very different needs. One autistic employee may require written instructions instead of rapidfire verbal directives; another may need noisecancelling headphones or predictable scheduling to avoid sensory overload. A professional with ADHD may be highly effective in clientfacing work but struggle with openended, unsupervised tasks unless given structure, deadlines or technological supports. Not all new hires will disclose their diagnoses, which can lead to a gray area for both the employee and the employer. Effective advocacy depends on understanding these individual profiles rather than treating all diagnoses the same.

Legal foundations: ADA, FEHA, and the duty to accommodate

At the federal level, the Americans with Disabilities Act (ADA) and its amendments define disability as a physical or mental impairment that substantially limits one or more major life activities, including concentrating, thinking and working. ADHD and autism can qualify, but courts have been inconsistent, especially where plaintiffs are high achievers or developed elaborate coping mechanisms.

California's Fair Employment and Housing Act (FEHA) goes further than the ADA in both scope and employee protection. An employee is disabled if they have a physical, mental or medical condition that limits a major life activity; "limits" is interpreted more broadly under FEHA than "substantially limits" under the ADA. The regulations explicitly state that "mental disability" includes intellectual or cognitive disability and "autism spectrum disorders" (Cal. Code Regs., tit. 2, § 11065(d)(1)). That textual recognition matters when advocating for autistic clients whose manifestations of disability have been unfairly labeled as indicia that they are merely "difficult" or "noncollaborative" in the workplace.

ADHD remains more contested. Some courts have been reluctant to find disability where the employee is relatively successful on paper or a performance review. Yet decisions have made clear that ADHD can constitute a qualifying impairment. In Kanne v. Kerry, the Central District of California's court recognized that prior precedent did not foreclose the possibility that ADHD could substantially limit major life activities, specifically distinguishing earlier cases that seemed skeptical of ADHDbased claims. And in Burtt v. Sunnova Energy Corp., a federal court applied FEHA held that ADHD constituted a disability where it made "work, a major life activity, more difficult for [the individual] as compared to the average person who does not have ADHD." This comparative, functional approach is consistent with FEHA's remedial purpose and should guide both counseling and litigation.

Common legal pitfalls and employer missteps

The most common employer mistake is treating neurodivergent behavior as purely disciplinary rather than disabilityrelated, or (even potentially related). Workers on the spectrum are reprimanded for "insubordination," "communication issues," or "failure to follow instructions" when the real problem is that expectations were never clearly conveyed in a format they can access.

Other frequent missteps include:

Refusing to engage in the interactive process once an employee discloses a diagnosis or requests help.

Demanding "cure" rather than accommodation--for example, insisting on traditional eye contact or brainstorming meetings when written input or oneonone conversations would be equally effective.

Relying on rigid "essential functions" descriptions that were never updated to reflect the actual job, then using those documents to deny accommodations that would not create undue hardship.

For plaintiffs' lawyers, these failures are fertile ground. Though neurodiversity is a nearly 30-year-old term, employers' track records often reveal employers do not consider (or simply overlook) alternative communication methods, flexible scheduling or environmental modifications, despite minimal cost and clear potential to improve performance. This can lead to an increased fear of stigma among employees particularly those with autism.

The role of attorneys in promoting neuroinclusive workplaces

Attorneys representing employees do more than litigate after the fact. They help neurodivergent workers name what they are experiencing, connect it to legal protections, and frame accommodation requests that are both specific and reasonable. That may involve translating "I am overwhelmed and always behind" into a request for written task lists, projectmanagement tools or fewer lastminute changes to deadlines.

In counseling and negotiations, counsel can reorient HR and management away from stereotypes toward functional analysis by asking:

What tasks are actually impacted?

Which major life activities are limited?

How do proposed accommodations mitigate those limitations without unduly burdening the employer?

In litigation, attorneys can educate courts about contemporary science, neurodiversity frameworks, and the breadth of FEHA's definition of mental disability, using cases like Kanne and Burtt to push back against outdated assumptions that ADHD is merely a matter of willpower.

Practical strategies for inclusion

From a practical standpoint, many of the most effective accommodations are modest, flexible and beneficial to the entire workforce. Examples include:

Information design: Providing key instructions in writing; using clear, concrete language; and avoiding ambiguous "ASAP" or "urgent" labels.

Environmental adjustments: Allowing noisecancelling headphones, quiet workspaces or predictable schedules where possible.

Executivefunction supports: Implementing shared calendars, taskmanagement systems or brief checkin meetings to clarify priorities.

Performance management with context: Framing feedback around specific behaviors and outcomes rather than generalized criticisms about "attitude" or "soft skills."

Employers who truly want to enable their workers' success should see these details as a floor, rather than a ceiling. They can also use resources such as ASKJAN.org for training on workplace accommodation topics.

Lawyers can help clients articulate these needs in the language of the interactive process and, when necessary, demonstrate that proposed accommodations are reasonable given the employer's size, resources and existing practices.

Broader policy trends and the future of disability law

Policy trends were already moving toward greater recognition of neurodiversity prior to 2026. The EEOC has issued guidance on ADHD and autism in the workplace, and state agencies increasingly recognize neurodevelopmental conditions as mental disabilities within the meaning of civil rights statutes. California's regulatory language expressly including autism spectrum disorders, and judicial acknowledgement that ADHD can be disabling when it makes work more difficult than for the average person, are concrete markers of this shift.

At the same time, gaps remain. Courts sometimes discount claims by highperforming professionals, reasoning that strong résumés undercut disability status. That reasoning ignores the steep "hidden costs" of constant masking, overcompensation and burnout. This could lead to the need for increased medical leave. Burnout, in particular, can manifest as depression, and an autistic or neurodiverse individual may need more time to recover from its impact.

Furthermore, the current presidential administration's frosty view toward diversity, equity and inclusion impacts neurodiverse individuals' rights and accommodations in the workplace--a concept that was overshadowed while targeting racial and ethnic diversity hiring practices. Future disability law could take the form of legislation, regulation, or evolving case law and will need to more directly address these dynamics if it is to fulfill the promise of equal opportunity.

Inclusion as a legal and moral imperative

Supporting neurodiverse workers is a matter of civil rights and legal compliance. The ADA and FEHA, particularly as interpreted to encompass autism spectrum disorders and ADHD that materially affect work, require employers to move beyond "onesizefitsall" workplaces and to engage sincerely in the interactive process.

For attorneys, the challenge and opportunity lie in bridging doctrine and authenticity: relaying stories of neurodivergent workers in ways that illuminate both the harm of exclusion and the feasibility of inclusion. When the law recognizes that everyone processes the world differently--and that this difference deserves accommodation, not punishment--it comes closer to its core purpose: expanding, rather than contracting, the circle of who gets to participate fully in public and economic life.

#1830

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