Federal Court Decides ADA Case

March 27, 2026

Important Takeaways: There is no general requirement under the ADA that an employee who has already provided medical documentation needs to provide updated medical documentation before triggering an obligation to continue the interactive process in good faith.

Facts: This case concerns a Michigan hospital’s employment practices. Megan Shefke, a charge nurse at William Beaumont Hospital (“Beaumont”), has Farby disease. Farby disease is a degenerative disorder with symptoms that gradually worsen over time. Shefke could no longer work more than 32 hours a week due to her illness. At that time, Beaumont had three vacant positions for which Shefke was qualified and sought consideration. Shefke asserted that Beaumont was obligated to transfer her to one of these positions as an accommodation under the Americans with Disabilities Act (“ADA”). However, Shefke did not provide Beaumont with medical records until the vacant positions had been filled. Beaumont told Shefke that the ADA requires an employer to transfer an employee only after the employee provides the employer with relevant medical documentation.

Shortly after Beaumont filled the vacancies, Shefke sought employment elsewhere and filed a discrimination claim against Beaumont for failing to participate in the interactive process required under the ADA to request an accommodation. Both parties moved for summary judgment, which may be granted only if the court determines that no reasonable jury could find for the other party.

Court findings: The ADA requires an employer to provide qualified employees with disabilities reasonable accommodations that will allow them to perform their essential job duties. When an employee can no longer perform the essential duties of their current job, reassignment to a vacant position may be a reasonable accommodation under the ADA. When an employee requests an accommodation, the employer must participate in good faith and conduct an individualized inquiry into possible accommodations.

Beaumont argued that its obligation to transfer Shefke to another position as an accommodation is not triggered until Beaumont receives medical documentation regarding her illness. Beaumont relied on Kirilenko-Ison v. Board of Ed. of Danville Independent Schools, in which the employee did not provide the employer with any medical documentation of the claimed disability. However, that case is distinguishable from Shefke’s because Beaumont had already received medical records from Shefke when it granted a prior accommodation and when Shefke took leave under the Family and Medical Leave Act (“FMLA”). Further, the court found that a requirement that an employee provide updated medical documentation before the employer takes any action on the employee’s accommodation request reflects bad faith on Beaumont’s part.

The court held that there is no general requirement under the ADA that an employee who has already provided medical documentation needs to provide updated medical documentation before triggering an obligation to continue the interactive process in good faith.

Next, the court examined whether Beaumont had a policy of pausing the interactive process until the employee provided updated documentation. In order to escape liability, Beaumont would have to show (1) a policy existed, (2) that Beaumont applied that policy to Shefke and relied on that policy when pausing the interactive process, (3) that the policy was applied in good faith under the circumstances, and (4) that the policy was clearly communicated during the interactive process.

Unfortunately for Beaumont, they presented no evidence that the hospital had such a policy, which defeats the analysis at step one. However, even if Beaumont had a policy of pausing the interactive process until the employee provided updated medical documentation, a jury would likely find the policy was not applied in good faith. Beaumont is a hospital that already had notice of its employee’s degenerative disorder. It would be hard for any hospital to articulate how this policy reflects a good-faith effort to participate in the interactive process. Finally, at no point was this policy clearly communicated to Shefke during the interactive process.

Thus, the court found that no reasonable jury could accept Beaumont’s argument that its obligation to participate in the interactive process is only triggered when the employee updates and informs the employer of relevant medical documentation.

On February 12th, 2026, Beaumont settled the case for $30,000.

What this means: By denying the hospital’s argument, the court clarified when an employer’s obligation to participate in the interactive process to request an accommodation is triggered. Employers still have the right to request documentation demonstrating the medical necessity of the accommodation. However, once the employer receives documentation of the disability, the employer cannot delay or suspend the interactive process.

EEOC v. William Beaumont Hospital, United States District Court Eastern District of Michigan Southern Division, November 19, 2025.

Please contact Bea, Megan, Kevin, Beth, or Kali if you have any questions.