The Washington Court of Appeals on April 20, 1993 reinstated a handicap discrimination claim brought by an asthmatic high school counselor who alleged that her employer school district failed to make reasonable accommodation regarding exposure to environmental tobacco smoke.  The court ruled that the claim was filed in a timely manner, in that the cause of action accrues when the employer makes a decision not to accommodate the employee’s handicap and that decision is communicated to the employee.

850 P.2d 536, 69 Wash. App. 445, 8.2 TPLR 2.230 (1993).