There has been a trend over the past several years of employers enforcing return-to-work policies. With return-to-work requirements, employers may see an increase in employees requesting Americans with Disabilities Act (“ADA”) accommodations to work from home, especially as advancements in technology make remote work possible., Employers may face the question of whether they should grant an employee’s request to work from home as a reasonable accommodation under the ADA. A recent case in the United States District Court for the Eastern District of Tennessee demonstrates that this is a fact-specific issue that employers should carefully consider to avoid ADA discrimination claims.

In Susie Monday v. U-T-Battelle, LLC, the District Court considered whether an employer violated the ADA when it terminated the plaintiff, a Senior Administrative Assistant, after she requested to permanently work from home due to an eye condition. 2026 WL 114978 (E.D. Tenn. Jan. 15, 2026). She previously worked remotely during the pandemic and also received temporary approval to work from home relating to her condition. Id. at *2, 6. The employer denied the plaintiff’s request and suggested the plaintiff use a taxi or ridesharing platform to commute to work and also offered to provide a guest pass for someone to drop her off. Id. at *2. The plaintiff refused these options, and the employer ultimately terminated her employment. Id. The plaintiff sued for ADA discrimination. Id.

The District Court determined that on-site attendance was an essential function of the plaintiff’s job because she needed to be immediately accessible and engage in face-to-face interaction and coordination with other employees. Id. at *6. The plaintiff argued that she had access to the same technology in-office as she did remotely to support her claim. Id. The Court determined that this argument “does not negate [the employer’s] judgment that in-person collaboration is required for plaintiff’s position.” Id. The Court also agreed with other courts’ holding that “the fact that defendant permitted remote work during the pandemic does not mean that in-person work is not essential to plaintiff’s position or that defendant abandoned its goal [] of returning to an in-person work environment.” Id. Since she could not perform an essential function of the job, on-site attendance, the Court determined she was not qualified for the position. Id. at *7.

This case illustrates that ADA accommodation requests for remote work can be denied under certain circumstances, even when the position was remote during the pandemic. Employers should carefully consider all the facts and evaluate whether an employee can perform the essential functions of their job remotely, whether remote work is reasonable under the circumstances, and whether there are alternative, reasonable accommodations to remote work.