Labor & Employment Law Daily Wrap Up, DISCRIMINATION—DISABILITY—E.D. Tenn.: Employee who rejected alternative accommodations, insisted on rolling chair, loses ADA claim, (Jul 23, 2026)

By Ursula Furi-Perry. J.D., MBA

Rejecting a proposed workstation modification that she admitted would have solved her problem, the employee could not pursue the failure-to-accommodate claim based on the denial of a rolling chair.

A former employee alleged that her employer violated the Americans with Disabilities Act (ADA) when, after she returned from extended medical leave following back surgery, it refused her request to continue using a rolling chair that she claimed was necessary to perform her job. The employer maintained that rolling chairs had been eliminated under a workplace safety policy and that it offered several alternative accommodations, including modifications to the employee's workstation, which she declined. A Tennessee federal court granted summary judgment for the employer on the ADA claim, finding that an employee is not entitled to a preferred accommodation when the employer offers another reasonable and effective accommodation. The court further concluded that the employee's rejection of proposed accommodations and return to medical leave prematurely ended the interactive process, preventing her from establishing that she was a qualified individual under the ADA (Leonard v. Lions Volunteer Blind Industries, Inc., No. 2:24-CV-00072-JRG-CRW (E.D. Tenn. July 20, 2026)).

In 2020, the plaintiff began working as an inspector for Lions Volunteer Blind Industries, a nonprofit organization providing textile manufacturing services. The employer’s mission includes employing individuals with disabilities, particularly those with visual impairments, and it regularly provides workplace accommodations for disabled employees.

Although the employee was not visually impaired, she suffered a disabling back injury in a 2019 automobile accident. When she was hired, she informed the employer that she had a disability, but she did not request any specific accommodation because she was already using a rolling chair at her workstation. She worked successfully in that position for approximately two years while using the chair, without incident.

Medical leave. In September 2022, the employee took extended medical leave after undergoing additional treatment for her back injury. During her absence, the employer removed the rolling chairs from the production floor as a safety measure after several employees had fallen while using them, including one worker who suffered injuries requiring stitches. Supervisors believed rolling chairs created a particular hazard because many employees at the facility were visually impaired and worked on concrete floors.

When the employee returned to work in April 2023 with a physician's release authorizing unrestricted work, her original rolling chair was initially available but later it was replaced with a stationary chair under the company's safety policy.

However, the employee experienced increased back pain using the stationary chair and requested that her rolling chair be returned. Instead, the employer proposed several alternative accommodations, including a swivel chair, repositioning her workstation and lighting, and modifying the workstation so she could perform her job without pushing or pulling her chair.

Refused to try. During her deposition, the employee acknowledged that the proposed workstation modification would have addressed her concerns, but she declined to try it and insisted that only a rolling chair would work.

After working only a few more days, she submitted another doctor's note taking her out of work indefinitely. Because she had exhausted both her FMLA leave and the employer's extended leave policy, Lions terminated her employment. She subsequently filed suit, bringing claims under the Americans with Disabilities Act and the Tennessee Disability Act. The employer filed for summary judgment.

Employee participation needed. The court first considered whether the former employee established a prima facie ADA claim. Although the parties agreed that she had a disability and requested accommodation, and that the employer denied her request for a rolling chair, the court found that the central issue was whether she remained a "qualified individual" under the ADA. To qualify, she had to demonstrate not only that she could perform the essential functions of her job with reasonable accommodation, but also that she participated in the interactive process in good faith.

Admitted it would have worked. The court concluded that the employer fulfilled its obligations by actively engaging in the interactive process and proposing several reasonable alternatives. Supervisors offered to modify the workstation, reposition the lighting, and provide a swivel chair that would eliminate the need to push or pull herself while working. Most importantly, the former employee admitted during her deposition that modifying the workstation would have solved her problem. Despite that admission, she refused to try the proposed modification and insisted that only a rolling chair would suffice. The court emphasized that an employee cannot require an employer to adopt a specific accommodation when another effective accommodation is available.

Prematurely ended it. The court further determined that the employee prematurely ended the interactive process: rather than continuing to work with the employer to identify an effective solution, she worked only three days after returning from leave before submitting another doctor's note removing herself from work indefinitely. The note contained no projected return date and identified no additional accommodation that might enable her to continue working.

Not a qualified individual. Because the employer actively participated in the interactive process while the former employee rejected reasonable alternatives and effectively withdrew from the process, the court held that she was responsible for the breakdown in communications. As a result, she was no longer considered a qualified individual under the ADA, and her failure-to-accommodate claim failed as a matter of law.

Additionally, the court declined to exercise supplemental jurisdiction over the employee's remaining claim under the Tennessee Disability Act. Because no federal claims remained, the court dismissed the state-law claim without prejudice, allowing the employee to pursue that claim in state court if she chose.

The case is No. 2:24-CV-00072-JRG-CRW.

Attorneys: E. Patrick Hull (Law Office of E. Patrick Hull) for Kathy Leonard. L. Eric Ebbert (The Ebbert Law Firm) for Lions Volunteer Blind Industries, Inc.

Companies: Lions Volunteer Blind Industries, Inc.

Cases: DisabilityDiscrimination Discrimination Discharge TennesseeNews