Federal Court Says Working From Home is Not Automatic Accommodation

April 28, 2015

A recent decision by the Sixth Circuit Court of Appeals held that the Equal Employment Opportunity Commission failed in its claim that Ford Motor Company violated the Americans With Disabilities Act by failing to accommodate an employee with irritable bowel syndrome when the employee requested to work from home on four days of the work week. 

The Court of Appeals held that Ford Motor Company did not violate the Americans With Disabilities Act when it refused to allow an employee to work from home on a regular and routine basis. The employee suffered from irritable bowel syndrome and found it difficult to come to work and interact with people in the workplace. Ford Motor Company did not honor the employee’s request to work from home four out of five days of the week arguing the job of Resale Buyer required on-site attendance as part of essential functions of the job. The employee tried to show working from home would be acceptable because other employees were allowed to work at home but on a less frequent basis.

The Court of Appeals ruled en banc (meaning all Justices participated) that it was not a reasonable accommodation to allow the employee to work at home as requested. The majority of the Justices said the Court should not give blind deference to the employer’s judgment on what is a reasonable accommodation but will grant summary judgment when the employer’s judgment regarding essential job duties is “job-related, uniformly enforced and consistent with business necessity.” 

This is a victory for employers because the Court acknowledges judgment made by a company as to what is a reasonable accommodation is something that must be given consideration by the Court if it is reasonable and consistent with business necessity. Employers must take care to make reasonable accommodation decisions on a case-by-case basis and provide rationale for the business reason for its decision.

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