paraphrase Employers may also be subject to liability for making an adverse employment decision based on an individual's lack of fluency in English, unless fluency is required to perform the primary job responsibilities associated with the position. For example, it might be necessary for individuals applying for managerial positions in a restaurant to be fluent in English, but the same degree of fluency might not be necessary for each of the cashiers the manager would supervise.33 The same limitations on an employer's right to require fluency in English are applicable to other fluency requirements. For example, an employer who has Spanish-speaking-only customers might have a legitimate business reason for hiring some Spanish-speaking employees, but this might not be sufficient reason to require Spanish fluency for all positions. Therefore, an employer might be prohibited from using Spanish fluency as the basis for disqualifying applicants because this could have a disparate impact on individuals based on their national origin. Based on these variations, employers should be certain that any fluency requirements are closely linked to a specific business need