ADA Accommodation Requests: Sixth Circuit Treats Failure to Use Employer’s Designated Process (After Repeated Referral) as No Request at All

1. Introduction

In Daniel Woodie v. Motorola Solutions, Inc (6th Cir. Mar. 10, 2025) (unpublished), Daniel K. Woodie, a traveling “Federal Systems Technologist” with nocturnal epilepsy, challenged his 2021 termination and alleged that Motorola (1) failed to accommodate his disability, (2) discriminated against him because of disability, and (3) retaliated against him for protected activity. The district court granted summary judgment to Motorola on all claims.

The appeal centered on a recurring ADA question: when an employee informally asks supervisors for schedule changes tied to a medical condition, but repeatedly declines to use the employer’s formal accommodation channel, has the employee “requested an accommodation” sufficient to trigger the ADA interactive process—and can later claim retaliation for making those requests?

2. Summary of the Opinion

The Sixth Circuit affirmed summary judgment for Motorola on all claims.

  • Failure to accommodate: The majority held Woodie did not make a legally sufficient accommodation request because Motorola had a defined process through Occupational Health Resources (OHR), supervisors and HR repeatedly directed him to it, and Woodie never contacted OHR.
  • Disability discrimination (discharge): The court found no direct evidence. Under the indirect (pretext) route, Motorola articulated legitimate reasons—performance, conflicts, insubordination, and stated desire to leave—and Woodie failed to show pretext.
  • Retaliation: Because Woodie did not request an accommodation under the ADA (per the majority), he did not engage in protected activity, defeating the prima facie case.

Judge Mathis concurred as to discrimination and retaliation, but dissented on failure to accommodate, reasoning that oral requests to supervisors can suffice; the failure to follow internal forms relates to the interactive process breakdown, not to whether a request was made at all.

3. Analysis

3.1. Precedents Cited

A. Procedural/summary judgment framing

  • Franklin Am. Mortg. Co. v. Univ. Nat'l Bank of Lawrence, 910 F.3d 270 (6th Cir. 2018): Cited for the de novo standard of review and the summary-judgment requirement of no genuine issue of material fact. This sets the appellate posture: the panel assesses whether Woodie produced evidence from which a reasonable jury could rule for him.

B. Failure-to-accommodate: request threshold and interactive process trigger (majority)

  • King v. Steward Trumbull Mem'l Hosp., Inc., 30 F.4th 551 (6th Cir. 2022): Supplies the prima facie elements for failure to accommodate and recognizes flexibility in how employees may request accommodations. The majority uses King to define the “request” element but ultimately reads the facts as not satisfying it.
  • Kirilenko-Ison v. Bd. of Educ. of Danville Indep. Schs., 974 F.3d 652 (6th Cir. 2020): Provides the principle that the interactive process obligation is triggered only after a request, and contains language the majority quotes for the proposition that employers are not obligated until the employee provides a proper diagnosis and requests a specific accommodation. The majority treats Woodie’s failure to contact OHR as fatal to the “request” requirement.
  • Gantt v. Wilson Sporting Goods Co., 143 F.3d 1042 (6th Cir. 1998): Cited for the rule that the employee bears the initial burden of requesting an accommodation. The majority relies on this allocation of responsibility to emphasize Woodie’s repeated refusal to invoke Motorola’s OHR channel.
  • Chaniott v. DCI Donor Servs., Inc., 481 F. Supp. 3d. 712 (M.D. Tenn. 2020): Raised by Woodie to argue that employer “idiosyncratic” policies cannot heighten the request standard. The majority rejects it as non-supportive, leaving the panel’s analysis controlled by Sixth Circuit authority.

C. Discrimination: direct evidence and pretext framework

  • Johnson v. Kroger Co., 319 F.3d 858 (6th Cir. 2003): Defines direct evidence as evidence requiring the conclusion that unlawful discrimination was at least a motivating factor. The majority uses Johnson to conclude that references to schedule-change requests were not direct evidence of disability discrimination.
  • Hrdlicka v. Gen. Motors, LLC, 63 F.4th 555 (6th Cir. 2023): Cited for the indirect burden-shifting structure (prima facie case → legitimate reason → pretext). The majority leans on Hrdlicka to frame why Woodie needed evidence undermining Motorola’s stated reasons.

D. Retaliation: protected activity requirement

  • A.C. ex rel. J.C. v. Shelby Cnty. Bd. of Educ., 711 F.3d 687 (6th Cir. 2013): Used for the prima facie requirement that the plaintiff engaged in protected activity. The majority’s conclusion that no ADA request occurred collapses the retaliation claim at step one.

E. Dissent’s accommodation-request and interactive-process authorities

  • Blanchet v. Charter Commc'ns, LLC, 27 F.4th 1221 (6th Cir. 2022) and Fisher v. Nissan N. Am., Inc., 951 F.3d 409 (6th Cir. 2020): Cited to characterize failure-to-accommodate claims as involving direct evidence (the failure itself) and to explain that “magic words” are unnecessary. The dissent uses Fisher to argue a factfinder could infer Woodie requested an accommodation through supervisor conversations.
  • Tchankpa v. Ascena Retail Grp., Inc., 951 F.3d 805 (6th Cir. 2020): Cited for the requirement that a plaintiff must propose a reasonable accommodation and for limits on entitlement when documentation is refused in certain contexts.
  • Bennett v. Hurley Med. Ctr., 86 F.4th 314 (6th Cir. 2023); Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007); Jakubowski v. Christ Hosp., Inc., 627 F.3d 195 (6th Cir. 2010); Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008): Used to define the employer’s duty to initiate and participate in an informal interactive process, and to analyze who caused the breakdown.
  • Root v. Decorative Paint, Inc., No. 23-3404, 2024 WL 4024426 (6th Cir. Sept. 3, 2024) and Wilson v. Ohio Department of Mental Health & Addiction Services, No. 23-3994, 2024 WL 3814047 (6th Cir. Aug. 14, 2024): The dissent cites Root for an employer duty “to inquire further,” and distinguishes Wilson as a case where the employer actually asked for paperwork/documentation.

3.2. Legal Reasoning

A. The majority’s core move: formal-process nonuse defeats the “request” element

The majority acknowledged factual evidence that Woodie at times tied schedule-change requests to his epilepsy (including supervisor recollections), and that modified schedules can be a reasonable accommodation in many cases. But it treated this as insufficient because Motorola maintained a Reasonable Accommodation Policy directing disability-related requests to OHR, and Woodie—despite repeated referral by supervisors and HR—never contacted OHR.

On that framing, the “request” element failed, so Motorola’s obligation to start the ADA interactive process never arose (as the majority read Kirilenko-Ison v. Bd. of Educ. of Danville Indep. Schs.). The doctrinal consequence was sweeping: no request → no failure to accommodate → no protected activity for retaliation.

B. Discriminatory discharge: no direct evidence; ample legitimate reasons; no pretext

Woodie attempted to treat Motorola’s references to his repeated schedule-change requests as direct evidence that he was fired for seeking accommodation. Applying Johnson v. Kroger Co., the majority held the evidence did not compel an inference of unlawful motive, especially because the court had already decided the schedule-change requests were not ADA accommodation requests and many were unrelated to disability.

Under the Hrdlicka v. Gen. Motors, LLC pretext framework, Motorola offered legitimate reasons supported by record evidence: removals from projects due to customer/coworker conflicts, combative communications, insubordination, and repeated threats to leave. Woodie’s post hoc explanation that medication influenced his conduct failed because he did not convey that explanation to Motorola until after termination, undercutting an inference that Motorola’s contemporaneous reasons masked discrimination.

C. Retaliation: “protected activity” depends on the majority’s accommodation-request holding

The retaliation claim hinged on whether Woodie engaged in protected activity by requesting an accommodation. Because the majority held he did not, A.C. ex rel. J.C. v. Shelby Cnty. Bd. of Educ. foreclosed the prima facie case.

D. The dissent’s competing rule: oral requests can be enough; process noncompliance concerns interactive-process breakdown

Judge Mathis’s dissent reframed the dispute: the threshold question is whether a factfinder could infer an accommodation request, and under Fisher v. Nissan N. Am., Inc., “magic words” are unnecessary. In the dissent’s view, once Woodie told supervisors he needed reduced travel because epilepsy impaired sleep, a jury could find he requested a reasonable accommodation. The internal policy then becomes relevant to whether Woodie or Motorola caused a breakdown in the interactive process under cases like Kleiber v. Honda of Am. Mfg., Inc. and Talley v. Family Dollar Stores of Ohio, Inc., not to whether a request occurred in the first place.

The dissent emphasized the employer’s duty to initiate an informal dialogue (citing Bennett v. Hurley Med. Ctr. and Jakubowski v. Christ Hosp., Inc.), and would allow a jury to decide whether Motorola “ignored” the requests by repeatedly deflecting them to HR/OHR without engaging on substance.

3.3. Impact

Although “NOT RECOMMENDED FOR PUBLICATION,” the majority opinion signals a practical rule that may influence ADA litigation strategy in the Sixth Circuit: when an employer has a clearly communicated accommodation channel and supervisors repeatedly direct the employee to it, an employee’s refusal to use it can be treated as failure to make an ADA accommodation request—potentially defeating not only accommodation claims but also retaliation claims premised on requesting accommodation.

The dissent highlights tension with broader Sixth Circuit language (particularly Fisher v. Nissan N. Am., Inc. and King v. Steward Trumbull Mem'l Hosp., Inc.) suggesting informality and “no magic words.” Future litigants can be expected to argue that Woodie should be limited to its facts: repeated, explicit referrals to a specialized department; a policy expressly making that department “responsible for processing requests;” and an employee who repeatedly declined.

For employers, the decision underscores the value of (1) a designated accommodation process, (2) repeated written referrals to that process, and (3) documentation that supervisors lack authority to approve disability accommodations outside the process. For employees, it underscores that persisting with informal requests while refusing to engage the designated mechanism may carry dispositive risk.

4. Complex Concepts Simplified

  • “Reasonable accommodation”: A change to the job or workplace that enables a qualified employee with a disability to perform the job (e.g., modified schedules), unless it causes undue hardship.
  • “Interactive process”: A back-and-forth communication between employer and employee to identify limitations and potential accommodations. The majority treated it as never triggered; the dissent treated it as triggered and potentially breached.
  • “Prima facie case”: The initial set of elements a plaintiff must show to get to a jury (here, including that the employee requested an accommodation).
  • “Direct evidence”: Evidence that, if believed, essentially proves discriminatory motive without inference (as defined in Johnson v. Kroger Co.).
  • “Pretext”: Proof that the employer’s stated legitimate reason is not the real reason and is a cover for discrimination (an issue governed here by Hrdlicka v. Gen. Motors, LLC).
  • “Protected activity” (retaliation): Actions the ADA protects from employer retaliation, such as making a valid request for accommodation.

5. Conclusion

Daniel Woodie v. Motorola Solutions, Inc turns on a single pivot point: whether Woodie’s repeated schedule-change requests amounted to an ADA accommodation request despite his refusal to use Motorola’s OHR process after repeated direction. The majority answered “no,” which simultaneously defeated the accommodation claim and the retaliation claim, and it upheld termination on nondiscriminatory performance grounds against the discrimination claim.

The dissent would have sent the accommodation issue to a jury, treating Woodie’s oral requests as sufficient and viewing policy noncompliance as part of the interactive-process breakdown analysis. The split frames a key takeaway for ADA practice: in the Sixth Circuit, the legal sufficiency of an “accommodation request” may depend not only on what the employee said, but also on whether the employee reasonably pursued the employer’s designated accommodation pathway when repeatedly instructed to do so.