California employers have discussed disability accommodation for decades, yet these claims remain easy to create accidentally—not because employers usually refuse accommodation outright, but because they skip steps, move too quickly, ask the wrong questions, rely too heavily on medical notes, or treat the process as a one-time decision.
The requests are also more complicated: remote work, modified schedules, intermittent leave, assistive devices, service animals, and extended leaves all require careful, individualized analysis.
Recognizing the Request Is the First Step
Employees do not need to use the words “reasonable accommodation” or identify a particular statute to put an employer on notice that an accommodation may be needed. But there are limits.
The California Court of Appeal’s 2026 decision in Husband v. Target Corp. provides an important reminder. The employee engaged in unusual and disturbing workplace behavior during what was later identified as a manic episode associated with bipolar disorder. He had not disclosed his diagnosis or requested an accommodation before the employer decided to terminate his employment.
The court rejected the argument that the employer should have recognized the behavior as the manifestation of a disability. An employer’s knowledge of an undisclosed disability will not ordinarily be inferred simply because an employee behaves strangely or a supervisor suspects something may be wrong.
Employers should not diagnose employees, but when an employee identifies a medical condition and connects it to a workplace problem or request for assistance, supervisors should involve Human Resources and recognize that the interactive process may have begun.
The Interactive Process Is More Than an Approval Form
Employers sometimes treat accommodation requests as applications to approve or deny. The better approach is to identify the employee’s limitations, determine which essential functions are affected, and explore reasonable accommodations that would allow the employee to perform the job.
The 2025 decision in Allos v. Poway Unified School District is instructive. The employee wanted to work entirely from home because of health concerns during the COVID-19 pandemic. Over more than two years, the district conducted six interactive meetings and provided various accommodations, including a hybrid schedule.
The employer did not treat the first request as a yes-or-no decision. It continued meeting with the employee and adjusting the arrangement as circumstances changed, which is the point employers sometimes miss: the interactive process is not a meeting; it is a process.
A Doctor’s Note Does Not Decide the Outcome
Medical documentation matters when the employee’s limitations or need for accommodation are not obvious, but medical providers do not decide what accommodation is reasonable for a particular workplace.
A note saying an employee “must work remotely,” “cannot work weekends,” or “should be transferred” provides information, but it should prompt the employer to understand the functional limitation behind the recommendation.
The provider supplies medical restrictions and limitations; the employer evaluates the job and possible accommodations; and the interactive process connects the two.
Essential Functions Must Reflect the Real Job
Employers cannot meaningfully evaluate an accommodation without understanding the job. That sounds obvious, but accommodation disputes frequently expose job descriptions that are years out of date or bear little resemblance to what the employee actually does.
Miller v. Department of Corrections and Rehabilitation, decided in 2024, demonstrates why essential functions matter. The employee was a correctional officer with significant physical restrictions. The Department identified duties she could no longer perform and explored alternatives, including placement in another position. The Court of Appeal ultimately upheld judgment for the employer.
The employer prevailed because it identified the actual physical requirements of the correctional officer position and showed why the employee could not perform them even with accommodation.
Employers should be able to answer practical questions: how often the function is performed, what happens if it is not performed, and whether reassignment would fundamentally change the position.
A job description is evidence. It should not be the entire analysis.
Exhausting Leave Does Not Necessarily End the Analysis
Another recurring problem arises when an employee exhausts statutory or employer-provided leave.
Employers sometimes assume that once protected leave ends, so does the accommodation obligation. That can be a costly mistake. Additional leave may itself constitute a reasonable accommodation. But that does not mean leave must continue forever.
Miller is useful here too. The employee had remained unable to work for years, and the court emphasized that FEHA protects employees who can perform the essential functions of the position with or without reasonable accommodation. Accommodation does not require an employer to eliminate essential job duties indefinitely.
The distinction is important. A request for another six weeks of leave accompanied by an anticipated return date presents a very different issue from a request for leave with no reasonably identifiable end point.
“Leave exhausted” should trigger analysis, not an automatic termination.
Safety Concerns Require an Individualized Assessment
Some accommodation cases involve legitimate safety concerns, and employers do not have to ignore genuine risks. But a diagnosis alone is not enough; the analysis must focus on the individual employee and the actual job.
Generalized assumptions about epilepsy, diabetes, mental health conditions, mobility limitations, or other disabilities are particularly dangerous. The more serious the employer believes the safety risk is, the more important it is to have objective information supporting that conclusion.
Good Documentation Cannot Replace a Good Process
Employers should document requests, communications, medical information, accommodations considered, decisions made, and follow-up—but documentation cannot substitute for engagement.
A perfectly completed form will not rescue an employer that never seriously considered alternatives. Conversely, a thoughtful interactive process can become difficult to defend when no one records what happened or why a particular decision was made.
The best accommodation files show both a genuine effort to solve the problem and a clear record of that effort.
Employers Should Be Able to Explain How They Got to “No”
Accommodation cases usually turn on process: whether the employer understood the employee’s limitations, identified essential functions, explored reasonable options, obtained appropriate information, and made an individualized decision.
Employers do not have to say “yes” to every request. But in California, they should be able to explain how they got to “no.”