What is the test for making a request for a reasonable accommodation?

As to the requirement that the requested accommodation be reasonable, "we have held that the plaintiff bears only a burden of production." Id.; see Gilbert v. Frank, 949 F.2d at 642. This burden "is not a heavy one.... It is enough for the plaintiff to suggest the existence of a plausible accommodation, the costs of which, facially, do not clearly exceed its benefits." Borkowski, 63 F.3d at 138. Having accomplished this, a plaintiff will have made a prima facie showing that a reasonable accommodation is available and the burden of nonpersuasion will shift to the defendant. See id.; Gilbert v. Frank, 949 F.2d at 642. The defendant must then show that the accommodation is not reasonable, or that it imposes an undue hardship, which "in practice ... amount to the same thing." Borkowski, 63 F.3d at 138 (collecting cases).

3. "Undue Hardship"