Reasonable accommodation does not mean giving an employee their first choice, and the interactive process runs in both directions. In Taylor v. IHC Health Services, a federal court in Utah ruled for the employer after an employee turned down an alternative accommodation and stopped participating in the conversation. ComPsych’s Ghadeer Sandouka walks through the case below.
What happened
Jolene Taylor, a hospital call center representative with several chronic conditions, asked for intermittent leave and permission to work from home. The hospital granted the leave but denied remote work, since no one in her role worked from home. It offered two alternatives: a more isolated office space and a specialized chair. The office change worked, but the chair stalled when Taylor declined to pick one, saying she was still hoping to work from home.
She later took continuous leave, never returned, and sued in late 2023. By summary judgment, her only remaining claim was failure to accommodate.
The decision
In August 2025, the U.S. District Court for the District of Utah ruled for the hospital on two grounds. The court found that Taylor caused the breakdown of the interactive process, and that she never showed working from home was a plausibly reasonable accommodation for her job. The hospital’s somewhat disorganized handling of the chair did not change the outcome.
Key takeaways for employers
- An employer may offer an alternative accommodation if it addresses the employee’s limitations and allows them to perform the essential functions of the job.
- Courts look closely at who continued the conversation and who stopped engaging.
- Evaluate remote work requests based on the actual job and real evidence, not assumptions.
- Document the request, the alternatives discussed, and each party’s response.
An important caveat: This is a district court decision, so it is persuasive authority and not binding precedent. It also does not give employers unlimited discretion, since the hospital’s alternatives were tied directly to the medical limitations in the doctor’s note.
Received an unfamiliar accommodation request? Reach out to your ADA coach before making a decision.
