Closely Related Small Businesses May Be Integrated to Secure ADA Coverage

May 10, 2022

As you may or may not know, companies with fewer than 15 employees are not covered by anti-discrimination laws, including the Americans with Disabilities Act (“ADA”). However, a recent court decision established that “integrated enterprises” (i.e., closely related small businesses) may be combined to secure ADA coverage.


Under what is known as the “integrated enterprise doctrine,” an employee can take legal action if they can show that their employer is “so interconnected with another employer that the two form an integrated enterprise” and, the integrated enterprise has at least the threshold number of employees to qualify for coverage from anti-discrimination law (i.e., 15 under the ADA). In making the determination as to whether two businesses can be considered one for ADA coverage, the court will whether the businesses have the same management team and whether the businesses have the same ownership, among other factors.


In a recent case out of California, an employee alleged that her employer, a law firm, was part of an integrated enterprise with another law firm. Evidence to support her claim included: a shared website, shared toll-free number, employees of both firms used the same email template footer which included the names of both firms, and even a shared IRS taxpayer ID number. Moreover, the same two attorneys own both firms. This was enough for the Court to hold that a jury could find the firms were an integrated enterprise and therefore, could be held liable for violations of the ADA.

This decision is important for owners of multiple small businesses as it is now possible for them to be combined for purposes of triggering coverage under federal anti-discrimination laws. Owners should note how closely related their businesses are and how this could impact their potential vulnerability to anti-discrimination lawsuits.


For more information on the ADA, or any other labor or employment law matter, please contact the attorneys at The Royal Law Firm LLP; (413) 586-2288. We know business matters! 

Brandon Calton admitted to the United States District Court of Connecticut

June 10, 2025
Brandon Calton is now admitted to the United States District Court, Connecticut! The Royal Law Firm is passionate about expanding our reach so that we can better serve our clients and their needs. Brandon is admitted in Massachusetts, the United States District Court of Massachusetts, and the United States District Court of Connecticut.

Federal Court Vacates EEOC’s “Abortion Accommodation Mandate” in PWFA

By Heather Child • June 9, 2025
On May 21, 2025, the U.S. District Court for the Western District of Louisiana struck down a provision in the Equal Employment Opportunity Commission’s (EEOC) final rule under the Pregnant Workers Fairness Act (PWFA), ruling that the agency exceeded its authority by requiring employers to accommodate elective abortions that are not medically necessary. Background Information: In June 2022, the U.S. Supreme Court issued a decision in Dobbs v. Jackson Women’s Health Organization, which overturned Roe v. Wade and eliminated the constitutional right to abortion. Congress passed the Pregnant Workers Fairness Act in December 2022, and it became effective in June 2023. The law requires employers with 15 or more employees to provide reasonable accommodation to qualified applicants or employees who have physical or mental conditions related to pregnancy, childbirth, or related medical conditions, unless doing so would cause significant difficulty or expense for the employer. In April 2024, The EEOC issued its final interpretation of the PWFA including abortion in the definition of “pregnancy, childbirth, or other related medical conditions” thereby requiring employers to provide accommodations related to abortion. In May 2024, the states of Mississippi and Louisiana sued the EEOC, arguing that the interpretation conflicted with the U.S. Supreme Court’s Dobbs decision and their respective state laws on abortion. In June 2024, Judge Joseph found that the EEOC exceeded its authority and issued a preliminary injunction postponing the effective date of the interpretation to provide accommodation for elective abortions until final judgment was entered in this matter. The final judgment was entered on May 21, 2025, that remanded the matter to the EEOC to revise the final rule and all related implementing regulations and guidances. Employer Takeaways: While employers are no longer (as of now) REQUIRED to provide accommodation for elective abortions, the remainder of the PWFA remains in full effect The decision to have or not have an abortion remains protected under Title VII The PWFA does not supersede state or local laws providing greater protection for pregnant workers. It is important to stay up to date on state regulations to ensure employers are complying with state laws. While it is still unclear how this ruling will impact employers nationwide, it is still important to continue to stay up to date on ever-changing legislation.  If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.