The Accommodation-Request Timeline That Keeps a Termination Defensible

A manager receives a service-animal accommodation request and a termination recommendation in the same week. Court records identified the plaintiff as Mr. Court records identified Vaden as a Putnam County, Tennessee, maintenance employee. A jury awarded him $333,349.01. Once he had the animal's medical paperwork and credentials, he requested that the service dog be allowed at his job. The complaint alleged that he was fired shortly after that request. The verdict came after a four-day trial in the Middle District of Tennessee, docket number 2:24-cv-00083. His service dog was valued at approximately $10,000 and was trained to assist with his condition.

The request date starts the timeline

A short interval between request and termination invites scrutiny when no documented exchange sits between them. The request date anchors the file because every later document is measured against it.

The file must show a two-way process

Title I of the ADA, the federal disability law, makes employers responsible for reasonable accommodation to qualified employees and applicants with disabilities unless the accommodation would impose undue hardship. Under EEOC enforcement guidance, unnecessary delay in responding to an accommodation request can itself be an ADA violation. A one-way denial email or a decision memo without genuine two-way discussion does not satisfy the interactive process.

Delay is the easiest failure. A request that sits unanswered while the termination decision is being drafted creates a timeline problem. The employer does not need to approve the accommodation immediately, but it needs to show that it was working through the question.

For a service animal, the request may include credentials, but the employer still must engage in the exchange. The notes capture whether the animal is needed for the job, whether the workplace can host it, and what alternatives were considered. If the answer is no, the memo explains the hardship.

• Request date: the employee asks for the accommodation with supporting documentation; the clock starts.
• Interactive-process notes: each conversation is recorded; a missing record means the process is not established.
• Decision memo: the termination reason is written independently; the file shows a business decision, not a reaction.
• Termination date: the employee is let go after the accommodation analysis is complete; the sequence closes the unexplained break.
• Settlement posture: the defense's last and best pretrial settlement offer was $35,000 before the award.

Good practice is to date the request, name the participants, and save the notes in the employee file. The record needs to show who asked what question, who answered, and what the employer decided next. A dated file gives the manager a clear sequence to explain to counsel.

The termination must stand alone

If an employee cannot return after FMLA leave ends, a termination letter issued before the employer completes the ADA accommodation analysis would likely violate the ADA. The termination memo must state the business reason, the decision-maker, and the date. It does not borrow language from the accommodation denial. The record must show that the decision would have been made even if the request had never arrived.

Keep the accommodation file and the performance file separate. If the termination is for conduct, the memo cites the conduct, the investigation, and the decision-maker. If the termination is for inability to return, the memo shows that the accommodation question was answered first.

Separate the decision-maker from the denial writer unless the record shows a separate review. If the denial and the termination are issued together, the file requires a clear explanation for why the decision was independent.

Filing volume makes the file matter

Plaintiffs filed 6,796 failure-to-accommodate cases in 2025, up about 42% from 2024, and federal discrimination filings first exceeded 20,000 that year. EEOC disability charge receipts reached a record 36,256 in fiscal year 2025. A low offer near the termination date can look like a guess. A higher offer after the file is complete can look like a reasoned position.