An employer did not violate the Americans with Disabilities Act by requiring an employee to provide additional documentation supporting her disability-related work restrictions, the 7th U.S. Circuit Court of Appeals has ruled.

The plaintiff was a patient access specialist who requested accommodations due to anxiety and depression.

She submitted a note from her nurse practitioner stating she could not work more than eight hours per day. The defendant, St. Vincent Health, requested further clarification from her healthcare provider to better understand the basis for the restriction.

When the plaintiff failed to provide additional documentation, the company did not implement the accommodation. She later resigned and sued, alleging failure to accommodate and retaliation under the ADA.

The 7th Circuit sided with the employer, affirming summary judgment in its favor.

The court issued the following findings:

Requesting medical clarification was lawful: Under the ADA, employers are entitled to request documentation that is “reasonable under the circumstances” to understand the nature of the disability and the need for accommodation.
No ADA violation: The employer’s request was limited and appropriate, and its refusal to implement the accommodation without proper documentation did not constitute a denial of rights.
No retaliation proven: The plaintiff’s resignation did not amount to constructive discharge, and there was no evidence of retaliatory intent.

Lessons for employers

The case demonstrates that, when evaluating accommodation requests, employers can lawfully seek additional documentation if initial submissions are vague or incomplete.

It is important to remember that the ADA only permits requests that are job-related and consistent with business necessity.

Keeping clear records of accommodation requests and follow-up efforts can provide key defenses if claims arise.

The ruling reinforces employers’ rights to seek clarification while also emphasizing the need for a measured and respectful interactive process.