The Fourth Circuit recently reminded employees of their shared obligation to participate in the interactive process with their employer when requesting a reasonable accommodation under the Americans with Disabilities Act (“ADA”). The case, Tarquinio v. Johns Hopkins University Applied Physics Lab, No. 24-1432 (4th Cir. 2025), makes clear that employees must provide their employers with requested documentation and information where the connection between their disability and its limitations on their work is not obvious.
The Facts
In September 2021, the Johns Hopkins University's Applied Physics Laboratory (“the Lab”) implemented a mandatory COVID-19 vaccination policy for employees. Employees were required to either be vaccinated or receive a medical or religious exemption.
The plaintiff, Sally Tarquinio, a systems engineer at the Lab, sought a medical exemption from the vaccine requirement, stating that she suffered from chronic Lyme disease and its lingering effects.
The plaintiff submitted a nine-year-old blood test and a form from her health care provider that cited Lyme disease as the basis for the exemption. However, because Lyme disease was not a medical contraindication to vaccination, the Lab asked her for more recent medical documentation and permission to contact her health care provider. The plaintiff declined, instead offering her own narratives, outdated articles, and a proposal for weekly testing and partial remote work. Without current documentation or authorization to verify her condition, the Lab denied her request as “insufficiently supported” and terminated her employment. The plaintiff sued under the ADA, alleging that the Lab did not accommodate her disability, fired her because of her disability, and subjected her to an unlawful medical examination.
The Holding
On appeal, the Fourth Circuit affirmed the district court's grant of summary judgment for the Lab, holding that the plaintiff prevented the employer from understanding the limitations of her disability, and therefore, the Lab's duty to accommodate never arose. In particular, the court said that the plaintiff disclosed her disability to the Lab, but did not explain, “beyond opaque references” why her disability prevented her from getting vaccinated, and the Lab had the right to ask for more objective evidence. The court found that the plaintiff prevented her employer from learning why her condition required the accommodations she requested, despite “ample opportunities.” As a result, she could not establish that her employer had a duty to accommodate her.
Key Takeaways for Employers
The Fourth Circuit's decision in Tarquinio offers several practical reminders for employers navigating ADA accommodation requests:
- The interactive process gives “employers and employees a chance to work together to figure out what accommodation, if any, would be reasonable and not unduly burdensome.”
- Where a disability and its limitations are not obvious, employers have the right to confirm whether employees have a genuine need for an accommodation, and need not simply take the employee's word for it.
- Sometimes, the connection between disability, limitation, and need for accommodation is obvious (e.g., a blind employee would not have to furnish medical records to establish the need for an accommodation to be able to review written reports). Once an employer knows that an employee has a disability that causes limitations that interfere with work, the employer must try to reasonably accommodate those limitations.
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