Why this matters in North Carolina (and Charlotte, Raleigh, Wilmington, Winston-Salem, and Asheville)
For employees across North Carolina, recent Fourth Circuit decisions sharpen a practical point under the Americans with Disabilities Act (ADA): the employer is not required to guess.
An employee seeking a reasonable accommodation must provide enough information to allow the employer to understand:
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that the request is related to a disability, and
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what workplace change is being sought.
When the need for accommodation is not obvious, the employee must also cooperate in providing reasonable medical information.
Two recent Fourth Circuit decisions—Kelly v. Town of Abingdon and Tarquinio v. Johns Hopkins University Applied Physics Laboratory—illustrate how courts analyze these issues.
1. The employee must “connect the dots” between the disability and the accommodation
The Fourth Circuit consistently describes the employee’s burden to request an accommodation as “light.” An employee does not need to use legal buzzwords, cite the ADA, or identify the perfect accommodation at the outset.
But the request must still do two things:
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identify a disability or medical condition, and
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indicate that the employee is seeking a workplace adjustment because of that condition.
In Kelly, the court rejected an accommodation claim even though the employee submitted a document titled “Accommodations Requests” and referenced the ADA. The problem was substance, not form. The employee failed to explain how the requested workplace changes related to his medical conditions. The court emphasized that employers are not required to infer or speculate about the connection.
Bottom line: Labels and buzzwords are not enough. The request must provide a “logical bridge” between the medical condition and the workplace change being requested.
2. Ambiguous requests may trigger clarification—but the employee must participate
When an employee’s request is unclear about the nature of the disability or the accommodation sought, the Fourth Circuit recognizes that the employer should seek clarification through the interactive process.
But the interactive process is not one-sided. An employee who wants ADA protection must participate in good faith. That means responding to reasonable questions and providing additional information when needed to clarify the request.
3. When the need is not obvious, medical documentation can be required
Tarquinio is an important warning for employees.
There, the employee requested a medical exemption from a COVID-19 vaccination requirement. The employer found the medical justification unclear and asked for updated documentation and permission to speak with the employee’s healthcare providers. The employee refused.
The Fourth Circuit ruled for the employer. The court held that when an employee presents an unusual or unclear medical basis for an accommodation, the employer is entitled to request reasonable documentation explaining:
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the medical condition, and
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the functional limitations requiring accommodation.
By refusing to provide that information, the employee prevented the employer from understanding whether an accommodation was required at all.
What information should an employee provide?
Based on recent Fourth Circuit guidance, an employee requesting an ADA accommodation should provide:
A. Clear notice that help is needed because of a medical condition
No legal citations are required, but the employer must be able to tell that the request is disability-related, not simply a workplace preference.
B. A description of the work-related limitation
The focus should be on functional limitations, such as:
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difficulty standing, lifting, or concentrating,
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need for breaks, schedule adjustments, or modified duties,
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limitations caused by treatment or episodic symptoms.
A diagnosis alone is usually not enough.
C. The accommodation being requested (or the type of change needed)
The employee does not have to identify the perfect solution, but the request must be concrete enough to start a real dialogue.
D. Medical documentation when reasonably requested
If the disability or need for accommodation is not obvious, the employee must cooperate with reasonable requests for documentation focused on functional limitations.
Best practices for employees requesting accommodations in North Carolina
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Make the request in writing.
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Clearly link the request to the medical limitation.
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Describe how the condition affects job duties.
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Propose one or more accommodation options.
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Respond promptly and reasonably to requests for medical support.
Refusing to provide clarification or documentation can be fatal to an ADA accommodation claim.
Sample accommodation request language
“I am requesting a reasonable accommodation for a medical condition that limits my ability to perform certain job functions. Because of this limitation, I am requesting [specific change], or an alternative accommodation that would allow me to perform my essential duties. I am happy to provide medical documentation regarding my functional limitations if needed.”
The takeaway
Fourth Circuit law is clear: employees do not need magic words to request a reasonable accommodation, but they must clearly communicate a disability-related need for a workplace adjustment and cooperate with reasonable requests for information.
A request that fails to explain the connection between the condition and the accommodation—or a refusal to provide reasonable medical support—can defeat an ADA claim before it ever reaches a jury.