Eleventh Circuit Employee Seeking Less Stressful Work Environment Denied ADA Protections
In a case addressing a challenging accommodation scenario faced by many employers, a Eleventh Circuit Court held in Hargett v. Florida Atlantic University Board of Trustees that an employee seeking a less stressful environment and an end to hostile confrontations with her manager was not seeking a reasonable accommodation. The employee suffered from epilepsy with seizures brought on by high tension and stress. She demanded as a reasonable accommodation that her supervisor cease his “hostile confrontations” with her. She also requested that her employer provide her with “calm, fair, non-confrontational treatment.”
The Court noted that asking a supervisor to adopt a less overbearing management style is generally not a reasonable accommodation. While “specific stressors…may in some cases be legitimate targets of accommodation, an employee cannot immunize herself from stress and criticism in general.” The employee failed to identify any specific stressors that her supervisor created and that her employer could address through the accommodation process.
When a request for accommodation is patently unreasonable, the employer may not have an obligation to investigate and engage in the interactive process. That is also the case if the demand for accommodation lacks sufficient specificity. While this decision was a good win for employers, it could be risky to ignore the interactive process altogether. In situations involving employees seeking a less stressful work environment due to a medical condition, the employer should start by asking the employee to identify the specific stressors that are causing the medical issues and which the employee is seeking to have eliminated or modified.