Court confirms ADA 'not a weapon' to force unnecessary accommodations

The U.S. 6th Circuit Court of Appeals (whose rulings apply to all Michigan and Ohio employers) recently upheld summary judgment (dismissal without a trial) for an Ohio employer that refused to grant a disabled employee's request to be permitted to work from home three days a week. According to the court, the employee failed to provide medical documentation supporting the need for the particular accommodation.

Facts

Kassi Tchankpa worked for Ascena Retail Group, Inc., as a database manager, providing 24-7 database support. The company required him to carry laptops to and from the office because database support personnel were often on call during nonbusiness hours.

Tchankpa allegedly injured his shoulder while transporting laptops in December 2012 but didn't report the injury to Ascena until May 2013. He claimed the injury impeded daily activities such as bathing, cooking, opening the refrigerator, and driving. He sought medical treatments for the pain from multiple healthcare providers and underwent various procedures until at least 2017.

Tchankpa repeatedly asked Ascena to let him work from home three days a week as an accommodation for the injury. The employer asked him to provide medical documentation supporting the request.

After some delay, Tchankpa did eventually provide a doctor's report, but it stated only that he (1) could perform his job as long as he could take intermittent breaks and (2) shouldn't lift anything heavier than 10 pounds. The report said nothing about his needing to work from home three days a week.