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How Specific Does An Employee Need To Make A Disability Accommodation Request?

by | Jun 4, 2024 | Disability Discrimination, Employment Discrimination, Employment Law, Federal Law Update |

Given recent changes to the law, the answer regarding the level of specificity needed to be given by an employee to the employer in order to request a disability accommodation is: Not Much.

Following the U.S. Supreme Court’s decision in Muldrow v. City of St. Louis, which made it easier for employees to demonstrate employment discrimination under Title VII of the Civil Rights Act of 1964, the United States Court of Appeals for the Sixth Circuit has expanded what employees should expect when requesting accommodations under Americans with Disabilities Act (“ADA”). In Yanick v. The Kroger Company of Michigan, the Sixth Circuit held that employers must consider all reasonable inferences from an employee’s statements and the context in which they are made to determine if a request for a reasonable accommodation has been made under the ADA. This is a monumental win for employees facing disability discrimination, reinforcing the power of their voices in the workplace. Let’s dig into this a little bit more.

What is the ADA?

The ADA, or Americans With Disabilities Act, is a groundbreaking federal law that prohibits discrimination against individuals with disabilities in all areas of public life, including jobs. It ensures that people with disabilities have the same rights and opportunities as everyone else. One crucial aspect of the ADA is the requirement for employers to provide reasonable accommodations to employees with disabilities. This means that if an employee has a disability, the employer must make adjustments or modifications to the job or work environment that allow the employee to perform their job duties.

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Can you give an example of a request for a disability accommodation that was sufficient under the ADA?

Mary Ellen Yanick managed a Kroger bakery for fifteen years, consistently meeting expectations. However, her work environment changed drastically the same week she was diagnosed with breast cancer and received a new supervisor, Marli Schnepp. Yanick faced persistent criticism and harassment from Schnepp, who held weekly meetings to discuss perceived deficiencies. These discussions often ended with Schnepp suggesting Yanick might consider stepping down, which Yanick interpreted as a recommendation for her to quit.

After taking medical leave for her breast cancer, Yanick returned to work with no work restrictions. However, the previous pattern of interactions with Schnepp resumed. When Yanick mentioned she was “struggling” and needed more time to adjust to new bakery programs, the supervisor dismissed her concerns. Within a month, Yanick stepped down and transferred to a different Kroger store.

After Yanick filed a lawsuit for disability discrimination, the United States District Court for the Eastern District of Michigan initially ruled in favor of Kroger, stating that Yanick’s requests were too vague and not explicitly tied to a medical condition. However, the Sixth Circuit disagreed, highlighting that employees don’t need to use specific terms like “accommodation” or “disability” to request help. Instead, the context and the need for adjustments should be enough to alert the employer.

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Can you explain the accommodation process under the ADA?

The accommodation process under the ADA involves an interactive dialogue between the employer and the employee. When an employee with a disability communicates the need for an adjustment, the employer is obligated to consider this request and engage in a conversation to determine what reasonable accommodations can be made. This process should be collaborative and aimed at finding the best solution that allows the employee to perform their job effectively.

In Yanick’s case, her statement that she was “struggling” and needed more time was deemed a valid request for accommodation. Given the context of her medical treatment, Kroger should have inferred that she needed adjustments to her work schedule. The Sixth Circuit ruled that Kroger failed to engage in the necessary interactive process, which could have included reasonable accommodations like a reduced work schedule.

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What are the key takeaways for employees following Yanick?

This ruling is a significant advancement for employees everywhere. It underscores the importance of recognizing and respecting the needs of employees with disabilities. No longer can employers hide behind vague requests and dismiss the struggles of their employees. The Sixth Circuit’s decision empowers employees, ensuring their voices are heard and their needs are met.

This is not just a legal win; it’s a victory for fairness and equality in the workplace. It’s a reminder that every employee, regardless of their physical or mental health challenges, has the right to work in an environment that supports their success. This ruling reinforces the idea that the best workplaces are those that accommodate and uplift their employees, creating a more inclusive and supportive work environment for everyone.

With Yanick in mind, these are the key takeaways that employees should best keep in mind:

  1. Communicate Clearly: While you don’t need to use specific legal terms, clearly communicate your need for adjustments due to a disability. Let your employer know if you are struggling and need help.
  2. Document Everything: Keep records of your communications with your employer regarding your disability and accommodation requests. This can be crucial if you need to take legal action.
  3. Understand Your Rights: Know that under the ADA, you are entitled to reasonable accommodations. This can include adjustments to your work schedule, modifications to your work environment, or other changes that help you perform your job.
  4. Seek Legal Advice: If you believe your employer is not complying with the ADA, consult with an experienced employment law attorney. A lawyer can help you understand your rights and take appropriate action to ensure you receive the accommodations you need.

Why Choose Spitz, The Employee’s Law Firm?

When it comes to protecting your rights as an employee, Spitz, The Employee’s Law Firm stands out as the best choice. As one of the largest law firms in the United States dedicated solely to employee rights, Spitz offers unparalleled resources, more attorneys, and extensive experience to fight for your case. They provide a free initial consultation, allowing you to discuss your situation without any financial obligation, ensuring you understand your options before making any decisions. Moreover, Spitz operates on a no-fee guarantee, meaning you don’t pay unless they win your case, eliminating any financial risk and ensuring their commitment to achieving the best outcome for you.

Spitz has a robust track record of securing favorable results for clients through their vast experience in employment law. Beyond their legal expertise, the attorneys at Spitz genuinely care about their clients, providing personalized support and empathy throughout the legal process. Their history of great results, demonstrated by significant settlements and verdicts, speaks volumes about their dedication to excellence and client satisfaction. Choosing Spitz, The Employee’s Law Firm, means having a powerful ally on your side, committed to fighting for your rights and ensuring justice is served.


The information provided in this disability discrimination blog is for general informational purposes only and should not be construed as legal advice regarding the ADA, Title VII, or other employment discrimination laws. While we strive to ensure the accuracy of the content, employment law is complex and can vary significantly depending on the jurisdiction and specific circumstances. The examples and scenarios discussed are meant to illustrate potential issues related to employee and employer rights, discrimination, and disability discrimination, but they do not cover all aspects of the law. Consulting with a qualified attorney or lawyer is essential for anyone facing employment law issues. Legal advice must be tailored to the individual facts and circumstances of each case, and a competent employment law attorney can provide the best guidance. Spitz, The Employee’s Law Firm, offers free initial consultations and a no-fee guarantee, ensuring that employees have access to the resources and expertise needed to protect their rights. We are committed to helping employees navigate the complexities of discrimination and disability discrimination cases with empathy and care. Remember, reading this blog does not create an attorney-client relationship. For personalized legal advice, please contact a licensed lawyer in your jurisdiction.

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