Fixed Sit–Stand Breaks as Facially Unreasonable ADA Accommodations in Fast‑Paced, Multitask Positions: Commentary on Bowles v. SSRG II, LLC (6th Cir. 2025)

I. Introduction

In Bowles v. SSRG II, LLC, No. 25‑5329 (6th Cir. Dec. 17, 2025), the U.S. Court of Appeals for the Sixth Circuit (Judge Readler, joined by Judges Boggs and Bush) affirmed summary judgment against an applicant who sought a front‑of‑house cashier/service position at a Chicken Salad Chick franchise. The applicant, Tawna Bowles, has knee arthritis and requested an accommodation allowing her to sit for five minutes after every ten minutes of standing.

The core holdings are:

• In a fast‑paced, front‑of‑house restaurant role whose essential functions require continuous mobility and multitasking, a request to sit for five minutes after every ten minutes of standing is facially unreasonable as a matter of law under the ADA and the corresponding Kentucky Civil Rights Act (KCRA).
• A claim for failure to engage in the ADA’s interactive process cannot stand independently where the employee has not first proposed a reasonable accommodation.

The opinion is recommended for publication, making it precedential within the Sixth Circuit. It clarifies how courts may dispose at summary judgment of accommodation claims where (1) the essential functions of the job and (2) the nature of the requested accommodation are undisputed, and the request necessarily removes or materially alters those essential functions.

II. Summary of the Opinion

Bowles applied for a cashier/service‑team member position at a Chicken Salad Chick in Crestview Hills, Kentucky. The role was front‑of‑house and, according to the employer’s job descriptions and testimony, required employees to:

• Operate the point‑of‑sale system (cash register);
• Stock the drink station and refrigerated chicken salad cartons;
• Expedite orders (take prepared food from the kitchen, prepare drinks, and deliver items to customers at the counter or tables);
• Clean tables, vacuum, remove trash, and maintain restroom and dining‑room cleanliness;
• Perform all of this in a “fast‑paced environment” with “well‑paced mobility” for the duration of the workday.

Bowles disclosed during her interview that she had difficulty standing for long periods. She was offered the job and, in her onboarding paperwork, indicated that she needed to be able to “sit down when needed” or “sit and work.” Human resources then requested medical documentation. Her physician provided a note asking that she be “supplied a chair for standing limitations due to knee arthritis.”

HR followed up, seeking more precision: how long Bowles could stand and how long and how often she would need to sit. Bowles ultimately requested an accommodation allowing her to stand for ten minutes at a time and then sit for five minutes, on a continuing basis across her shift. The company concluded it could not accommodate that request in the cashier/service‑team member role and stated that it did not have a continuously seated position available.

Bowles sued under the ADA and the KCRA, alleging:

1. Failure to accommodate her disability by denying her request “to sit for a duration of five minutes after every ten minutes of standing”; and
2. Failure to engage in the ADA’s interactive process.

The district court granted summary judgment to the employer. On de novo review, the Sixth Circuit:

• Assumed without dispute that Bowles was disabled and otherwise qualified for the position;
• Held Bowles failed to meet her initial burden of showing that her requested accommodation was objectively reasonable in light of the essential functions of the job;
• Concluded that the requested accommodation would fundamentally alter the cashier/service‑team role by limiting Bowles to a largely stationary cash‑register post and forcing coworkers to absorb essential multitask duties;
• Rejected Bowles’s interactive process claim because such a claim requires that the employee first propose a reasonable accommodation.

Accordingly, the court affirmed judgment for SSRG II, LLC, doing business as Chicken Salad Chick.

III. Legal Framework

A. ADA and KCRA Alignment

Bowles brought claims under both the federal Americans with Disabilities Act of 1990 (ADA) and the Kentucky Civil Rights Act (KCRA). The Sixth Circuit reiterated its standard practice of treating KCRA disability claims as coextensive with ADA claims:

• Kentucky Supreme Court: Barnett v. Central Kentucky Hauling, LLC, 617 S.W.3d 339, 343 (Ky. 2021) — KCRA serves as the state‑law vehicle implementing ADA‑type protections.
• Sixth Circuit practice: See Kirilenko‑Ison v. Bd. of Educ. of Danville Indep. Schs., 974 F.3d 652, 661, 669 (6th Cir. 2020); Bryson v. Regis Corp., 498 F.3d 561, 574 (6th Cir. 2007).

Thus, the analysis proceeded “in one fell swoop” for both statutes.

B. Reasonable Accommodation and Burden-Shifting

Under 42 U.S.C. § 12112(a) and (b)(5)(A), the ADA prohibits discrimination against a “qualified individual with a disability” and defines discrimination to include:

“not making reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability... unless [the employer] can demonstrate that the accommodation would impose an undue hardship.”

The Sixth Circuit employed a burden‑shifting framework (citing, inter alia, Rorrer v. City of Stow, 743 F.3d 1025 (6th Cir. 2014)):

1. Employee’s initial burden:
   • Show disability;
   • Show that she is an “otherwise qualified” individual for the position in question;
   • Show that the employer knew of her disability;
   • Show that the requested accommodation is “objectively reasonable” and would enable her to perform the essential functions of the job.
2. Employer’s burden of production (if step 1 is satisfied):
   • Demonstrate that the proposed accommodation would impose an undue hardship in the employer’s particular circumstances (citing King v. Steward Trumbull Mem’l Hosp., Inc., 30 F.4th 551, 560 (6th Cir. 2022); Walsh v. United Parcel Serv., 201 F.3d 718, 726 n.3 (6th Cir. 2000); Monette v. Elec. Data Sys. Corp., 90 F.3d 1173, 1183 n.10 (6th Cir. 1996)).
3. Employee’s rebuttal burden:
   • Offer evidence to rebut the employer’s showing of undue hardship (see Talley v. Fam. Dollar Stores of Ohio, Inc., 542 F.3d 1099, 1108–09 (6th Cir. 2008); Smith v. Midland Brake, Inc., 180 F.3d 1154, 1179 (10th Cir. 1999) (en banc)).

Importantly, the court emphasized that the ultimate burden of persuasion remains on the plaintiff to show unlawful discrimination (citing White v. York Int’l Corp., 45 F.3d 357, 361 (10th Cir. 1995), in turn citing St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502, 511 (1993)).

Here, the case stops at the threshold: Bowles failed to show her accommodation request was objectively reasonable given the job’s essential functions.

C. Essential Functions and “Per Se Unreasonable” Accommodations

An accommodation that would eliminate or fundamentally alter an essential function of the job is “per se unreasonable.” The court relied on:

• Jakubowski v. Christ Hosp., Inc., 627 F.3d 195, 202 (6th Cir. 2010) (accommodation must allow performance of the essential functions);
• EEOC v. Ford Motor Co., 782 F.3d 753, 761 (6th Cir. 2015) (en banc) (accommodation that eliminates an essential function is per se unreasonable);
• Keith v. County of Oakland, 703 F.3d 918, 927 (6th Cir. 2013) (plaintiff’s initial burden includes showing the proposed accommodation is efficacious and proportionate to costs in the “run of cases”).

The core dispute, therefore, was whether Bowles’s request for five minutes of sitting after every ten minutes of standing would still allow performance of the essential functions of a cashier/service‑team member in a fast‑casual restaurant.

D. Interactive Process

The ADA’s regulations contemplate an “informal, interactive process” between employer and employee to identify appropriate accommodations. But the Sixth Circuit has repeatedly held that a failure to engage in that process is actionable only if the employee has first proposed a reasonable accommodation. The court cited:

• Rorrer, 743 F.3d at 1041;
• Thompson v. Fresh Prods., LLC, 985 F.3d 509, 525 (6th Cir. 2021);
• EEOC v. Ford Motor Co., 782 F.3d at 766.

Because the court found Bowles’s only properly framed accommodation request to be facially unreasonable, the interactive‑process claim necessarily failed.

IV. Detailed Analysis of the Court’s Reasoning

A. Defining the Essential Functions of the Cashier/Service‑Team Role

The court treated the definition of the job’s essential functions as a largely factual question, driven by “the employer’s words, policies, and practices” (Ford Motor Co., 782 F.3d at 765–66). The record was “overwhelming and undisputed.”

1. Evidence the court relied on

• Written job descriptions:
  • For the cashier/service‑team member: expediting orders, assisting with dining‑room service, restocking drink stations, emptying trash, cleaning restrooms and equipment, in addition to operating the register.
  • For team members generally: working in a “fast‑paced environment” requiring “well‑paced mobility” for the duration of the workday.
• Statutory weight of job descriptions: 42 U.S.C. § 12111(8) expressly provides that an employer’s written job description “shall be considered evidence of the essential functions of the job.”
• Testimony from the restaurant manager and the Vice President of Human Resources confirming that:
  • The role was a front‑of‑house, generalist position;
  • Employees in this role routinely shifted between multiple tasks on demand; and
  • There was no standalone “register‑only” job.
• Photographs and historical practice showing active movement of team members and “very limited breaks,” reinforcing that constant mobility and versatility were expected.
• Industry understanding of “front of house” work, referencing Jones v. Gulf Coast Rest. Grp., 8 F.4th 363, 366 n.2 (5th Cir. 2021), which defined front of house as the part of a restaurant that deals directly with customers.

Taken together, this evidence established that the job required:

• Continuous, not sporadic, mobility;
• Multitasking across multiple functional areas (register, delivery of food to tables, stocking, cleaning);
• Rapid response to dynamic customer and operational needs.

2. Job title vs. job duties

Bowles argued that she was hired merely to “run the register,” suggesting a narrower list of essential duties. The court rejected that as inconsistent with the record:

• There was no formal “register‑only” position;
• The only relevant position in the record was the broader cashier/service‑team member role;
• Colloquial references to “cashier” did not alter the underlying job content.

Citing Stone v. City of Mount Vernon, 118 F.3d 92, 99 (2d Cir. 1997), the court emphasized that ADA analysis must focus on “the fundamental job duties of the employment position” rather than “solely on the title.” The Sixth Circuit treated the title as almost irrelevant next to the actual, undisputed list of essential functions.

B. Why the Requested Accommodation Was Facially Unreasonable

Bowles’s complaint and briefing consistently characterized her accommodation request as:

Being able to “sit for a duration of five minutes after every ten minutes of standing.”

The court took that formulation as controlling, noting that employees cannot shift their requested accommodation for the first time during litigation or on appeal (citing Tchankpa v. Ascena Retail Grp., Inc., 951 F.3d 805, 813 (6th Cir. 2020); Stover v. Amazon.com, LLC, 2022 WL 94608, at *4 (6th Cir. Jan. 10, 2022)). The “specific accommodation” analyzed must match the one pleaded.

1. Transforming the essential nature of the position

The court reasoned that enforcing a mandatory cycle of 10 minutes standing / 5 minutes sitting, throughout the shift, would:

• Effectively tie Bowles to the cash register for a third of her shift, even when no customers were present;
• Render her unavailable to:
  • Greet customers at the door;
  • Run food from the kitchen to tables;
  • Clean tables, spills, or restrooms;
  • Restock the beverage station or cooler;
  • Respond to spontaneous needs characteristic of a fast‑casual restaurant.
• Force other team members to assume those physically mobile, multitask functions during Bowles’s sitting intervals.

This, in the court’s view, would “fundamentally alter” the role from a “jack‑of‑all‑trades” to a “master of the cash register,” citing:

• Kiphart v. Saturn Corp., 251 F.3d 573, 584 (6th Cir. 2001) (quoting 29 C.F.R. § 1630.2(n) app.);
• Anderson v. Coors Brewing Co., 181 F.3d 1171, 1177 (10th Cir. 1999) (an accommodation that converts a multitask job into one requiring an employee to “sit in one place and perform one task” fundamentally changes the position).

2. Reallocation of essential functions to coworkers

The court also highlighted the spillover effect on other employees. Because Bowles would be constrained to the register during every five‑minute sitting interval, other workers would have to absorb the fast‑paced, mobile tasks. This is forbidden “reallocation of essential functions”:

• Kellar v. Yunion, Inc., 157 F.4th 855, 878 (6th Cir. 2025) (quoting Cooper v. Dolgencorp, LLC, 93 F.4th 360, 372 (6th Cir. 2024)) — a request to reassign essential functions to coworkers is not a reasonable accommodation;
• Anderson, 181 F.3d at 1177 — no legal obligation to make other employees perform “all of the operation’s demanding tasks while Plaintiff performs only certain light tasks.”

In ADA doctrine, employers are obligated to accommodate disabilities by, for example, modifying policies or non‑essential duties, but they are not required to remove essential functions or distribute them to others.

3. The “fast‑paced environment” and randomness of tasks

Bowles argued that she could perform some tasks during the standing portions of each 15‑minute cycle. The court found this immaterial:

• The nature of a fast‑casual front‑of‑house job is that tasks arise unpredictably — one minute a food order must be run to a table; the next, a table must be cleared or a spill wiped; the next, the beverage station must be restocked.
• The accommodation would, by design, make Bowles unavailable for some portion of these tasks each cycle, regardless of need.

That inherent mismatch between the irregular timing of essential duties and the rigid sit–stand cycle meant the accommodation could not be reconciled with the job’s essential requirements.

C. Distinguishing Prior “Stool/Chair” Accommodation Cases

Bowles relied heavily on two prior Sixth Circuit cases in which the use of a seat was deemed potentially reasonable:

• Talley v. Family Dollar Stores of Ohio, Inc., 542 F.3d 1099 (6th Cir. 2008);
• Gleed v. AT&T Mobility Servs., LLC, 613 F. App’x 535 (6th Cir. 2015).

The court distinguished both.

1. Talley (retail cashier with stool)

In Talley, the plaintiff requested permission to use a stool while performing register duties at a retail store. The court had held that:

• The plaintiff could perform register tasks with a stool;
• The job in question did not require continuous mobility to the same degree as here.

The nature of the job in Talley made occasional seated work at a stationary register more compatible with its essential functions.

2. Gleed (mobile phone retailer)

In Gleed, the plaintiff sold mobile phones in a store and previously sat most of the day. The court noted that “prolonged standing” was not presented as an essential function of that salesperson position; seating did not conflict with essential duties.

3. Why those cases did not control Bowles

Here, by contrast, the job was not “stationary, sales‑only.” The record showed that:

• The role required continuous movement across the dining area, kitchen pass‑through, and beverage stations;
• Customer‑facing duties were not limited to ringing up purchases;
• Cleaning, stocking, and delivering food were core, not incidental, duties.

Thus, the earlier “stool” cases did not establish a general right to seated work for all customer‑facing retail or restaurant jobs. Instead, each case depends on whether mobility is truly an essential function. In Bowles, the court concluded that it plainly was.

D. The Vague “Sit When Needed” Request

Bowles pointed to her interview statement and onboarding forms where she indicated she needed to “sit down when needed” or “sit and work,” arguing that a jury could find such a general request reasonable. The court rejected this argument on two grounds:

1. Lack of specificity:
   • Simply saying “I need to sit” with no details on frequency, duration, or impact on duties “amounts to no accommodation request at all.”
   • Citing Cassidy v. Detroit Edison Co., 138 F.3d 629, 635 (6th Cir. 1998), and Gantt v. Wilson Sporting Goods Co., 143 F.3d 1042, 1046–47 (6th Cir. 1998), the court reiterated that employers are not required to speculate about the nature or extent of an accommodation needed.
   • The Eleventh Circuit’s decision in Luna v. Walgreen Co., 347 F. App’x 469, 472 & n.2 (11th Cir. 2009), similarly rejected a bare “I need to sit at work” statement that did not specify “how long” or “for what intervals.”
2. Inconsistency with her articulated need:
   • Bowles clarified in both her complaint and her reply brief that she specifically needed to sit five minutes for every ten minutes of standing.
   • She confirmed that merely sitting while at the register when convenient would not suffice for her medical condition.
   • Given this, the court treated the rigid 10/5 sit–stand cycle as the actual requested accommodation, not a flexible “sit as needed” arrangement.

This reasoning underscores a practical point: employees must articulate their limitations and needed accommodations with enough specificity for an employer to understand and evaluate them. Vague references to a need to sit, especially when later replaced by stricter requirements, will not suffice.

E. Mixed Questions, But Suitable for Summary Judgment

Bowles invoked Sixth Circuit language suggesting that what constitutes an essential function and what is a reasonable accommodation are typically fact questions for a jury. The court acknowledged that:

• The inquiries are “highly fact specific” (Mosby‑Meachem v. Memphis Light, Gas & Water Div., 883 F.3d 595, 605 (6th Cir. 2018));
• Courts have often said these issues are “generally” for the jury (citing Blanchet v. Charter Commc’ns, LLC, 27 F.4th 1221, 1229–30 (6th Cir. 2022); Keith, 703 F.3d at 927; Haschmann v. Time Warner Ent. Co., 151 F.3d 591, 601 (7th Cir. 1998)).

But the court clarified that:

• These are mixed questions of law and fact (citing Koessel v. Sublette Cnty. Sheriff’s Dep’t, 717 F.3d 736, 743 (10th Cir. 2013));
• Summary judgment remains appropriate where there are “few evidentiary disputes” on the material facts (citing Payne v. Novartis Pharms. Corp., 767 F.3d 526, 530 (6th Cir. 2014), applying Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986)).

Here:

• The content of the job (essential functions) was undisputed;
• The nature and terms of Bowles’s request were undisputed;
• The only question was whether the request, in light of these facts, was legally reasonable — a determination the court treated as suitable for resolution as a matter of law, consistent with prior cases like Cooper, Ford Motor, and Williams v. AT&T Mobility Servs. LLC, 847 F.3d 384, 394 (6th Cir. 2017).

F. The Interactive Process Claim

Finally, Bowles argued that Chicken Salad Chick failed to properly engage in the ADA’s interactive process — pointing to:

• The one‑month gap between her supposed start date and the rescission of the job offer;
• The absence of any proposed alternative accommodations from the employer.

The court’s response proceeded in two steps.

1. Failure to engage is not an independent wrong

Relying on a line of Sixth Circuit authority, the court reiterated that:

• “Failure to engage in the interactive process does not give rise to an independent claim; it is a violation of the ADA only if plaintiff establishes a prima facie case of failure to accommodate” (Thompson, 985 F.3d at 525);
• That prima facie case requires that the plaintiff have proposed a reasonable accommodation (Rorrer, 743 F.3d at 1041; Keith, 703 F.3d at 929; Breitfelder v. Leis, 151 F. App’x 379, 386 (6th Cir. 2005));
• EEOC v. Ford Motor Co., 782 F.3d at 766, is to the same effect.

Because Bowles’s single well‑defined request was facially unreasonable, there was no viable interactive‑process claim.

2. No duty to propose a “counter accommodation”

The court added that employers have no legal obligation to suggest alternative accommodations if the one proposed is unreasonable. Citing Jakubowski v. Christ Hosp., Inc., 627 F.3d 195, 203 (6th Cir. 2010) (relying on Talley), the court emphasized:

• The interactive process is a shared responsibility, not a unilateral duty on the employer;
• Rejected accommodation proposals do not automatically trigger a duty to make counteroffers.

While the court acknowledged that Bowles “may be frustrated” by how quickly the employer reached its conclusion and by the lack of alternative proposals, such frustrations do not translate into liability absent a reasonable, feasible accommodation request.

V. Precedents Cited and Their Influence

A. Core ADA Framework Cases

• Rorrer v. City of Stow, 743 F.3d 1025 (6th Cir. 2014):
  • Provided the burden‑shifting structure for failure‑to‑accommodate claims;
  • Confirmed that the employee must show a reasonable accommodation; otherwise, the interactive process claim fails.
• EEOC v. Ford Motor Co., 782 F.3d 753 (6th Cir. 2015) (en banc):
  • Key authority on per se unreasonableness of accommodations that remove essential job functions;
  • Clarified the evidentiary approach to identifying essential functions;
  • Reappears here both on the essential functions analysis and the interactive process doctrine.
• Keith v. County of Oakland, 703 F.3d 918 (6th Cir. 2013):
  • Quoted on the employee’s need to show an accommodation is efficacious and proportionate to costs “in the run of cases” concerning that job;
  • Also cited regarding jury involvement in these typically fact‑intensive inquiries, which the court then cabins by emphasizing the appropriateness of summary judgment where facts are undisputed.
• Cooper v. Dolgencorp, LLC, 93 F.4th 360 (6th Cir. 2024):
  • Reinforced that an employee’s proposal must be “objectively reasonable” as a threshold matter;
  • Referenced in conjunction with Kellar for the rule that reallocating essential functions to coworkers is not reasonable.
• Kellar v. Yunion, Inc., 157 F.4th 855 (6th Cir. 2025):
  • Relied on to hold that a request to reallocate essential functions is categorically unreasonable as an accommodation.

B. Cases on Vague or Shifting Accommodation Requests

• Cassidy v. Detroit Edison Co., 138 F.3d 629 (6th Cir. 1998) & Gantt v. Wilson Sporting Goods Co., 143 F.3d 1042 (6th Cir. 1998):
  • Used to reject Bowles’s argument that a generic “sit when needed” statement sufficed as a request for accommodation;
  • Reaffirm the rule that employers need not guess at the type or extent of an employee’s needs.
• Luna v. Walgreen Co., 347 F. App’x 469 (11th Cir. 2009):
  • Persuasive authority rejecting a similarly vague “I need to sit at work” claim without specification of intervals or durations.
• Tchankpa v. Ascena Retail Grp., Inc., 951 F.3d 805 (6th Cir. 2020) & Stover v. Amazon.com, LLC, 2022 WL 94608 (6th Cir. Jan. 10, 2022):
  • Stand for the principle that employees cannot retroactively refine or invent new accommodations in litigation;
  • Require consistency between the accommodation pleaded in the complaint and the one defended at summary judgment.

C. Cases on Interaction and Employer Duties

• Thompson v. Fresh Prods., LLC, 985 F.3d 509 (6th Cir. 2021) & Rorrer:
  • Confirm that interactive process claims are not standalone if there was no reasonable accommodation to begin with.
• Jakubowski v. Christ Hosp., Inc., 627 F.3d 195 (6th Cir. 2010):
  • Relied upon to reject any notion that employers must propose “counter accommodations.”
• Banks v. Bosch Rexroth Corp., 610 F. App’x 519 (6th Cir. 2015):
  • Quoted in Tchankpa and referenced here to describe the interactive process as “informal” and collaborative.

D. Cases on Essential Functions and Mixed Questions

• Mosby‑Meachem v. Memphis Light, Gas & Water Div., 883 F.3d 595 (6th Cir. 2018):
  • Emphasized the fact‑specific nature of the essential functions inquiry.
• Blanchet v. Charter Commc’ns, LLC, 27 F.4th 1221 (6th Cir. 2022); Haschmann v. Time Warner Ent. Co., 151 F.3d 591 (7th Cir. 1998):
  • Illustrated the general presumption that reasonableness and essential functions are jury questions.
• Koessel v. Sublette Cnty. Sheriff’s Dep’t, 717 F.3d 736 (10th Cir. 2013):
  • Cited to label these as “mixed questions of law and fact,” thus supporting summary judgment where facts are undisputed.
• Payne v. Novartis Pharms. Corp., 767 F.3d 526 (6th Cir. 2014) & Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986):
  • Reinforce the general appropriateness of summary judgment in mixed‑question contexts when no material factual disputes exist.

E. State Law & General Principles

• Barnett v. Cent. Ky. Hauling, LLC, 617 S.W.3d 339 (Ky. 2021); Kirilenko‑Ison; Bryson:
  • Collectively confirm the alignment of KCRA disability standards with ADA jurisprudence, validating the court’s unitary analysis.
• White v. York Int’l Corp., 45 F.3d 357 (10th Cir. 1995) & St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (1993):
  • Cited to underscore that the burden of persuasion on discrimination always rests with the plaintiff.

VI. Simplifying Key Legal Concepts

A. “Essential Functions” of a Job

An essential function is a fundamental duty of a position — a core task that the job exists to perform. The ADA does not require employers to remove or permanently shift essential functions to others.

How courts identify essential functions:

• Written job descriptions;
• Actual workplace practices and policies;
• Testimony from managers and coworkers;
• Whether the function is highly specialized or central to the job’s purpose;
• Consequences of not requiring that function.

In Bowles, essential functions included:

• Continuous mobility throughout the front of the house;
• Ability to multitask among register, food expediting, stocking, and cleaning.

B. Reasonable Accommodation

A reasonable accommodation is a change to the workplace or to job procedures that enables a disabled employee to perform essential functions, without creating an undue hardship for the employer.

Examples (in general):

• Modified work schedules;
• Reassignment of nonessential duties;
• Assistive devices or modified equipment;
• Policy adjustments (e.g., allowing extra breaks when consistent with essential duties).

Not reasonable:

• Eliminating essential functions of the position;
• Reallocating essential duties to other employees;
• Accommodations that fundamentally alter the nature of the job.

C. “Objectively Reasonable” vs. Employee Preference

The focus is on whether an accommodation is objectively reasonable given the duties, not whether it matches the employee’s preferred solution. The employee must show that, in the “run of cases” for that position, the proposed accommodation would work without destroying essential job functions or imposing undue hardship.

D. Undue Hardship (Though Not Reached Here)

Undue hardship refers to significant difficulty or expense for the employer, considering factors like:

• Nature and cost of the accommodation;
• Employer’s size and resources;
• Impact on operations, including workforce structure and other employees.

In Bowles, the court never reached undue hardship because it found the accommodation facially unreasonable at the threshold.

E. Interactive Process

The interactive process is an informal, back‑and‑forth dialogue where employer and employee:

• Clarify the employee’s limitations;
• Discuss possible accommodations;
• Assess feasibility and impact.

But:

• The employee must initiate or at least clearly request an accommodation;
• The employee must propose an accommodation that is at least arguably reasonable;
• The employer is not required to invent accommodations out of whole cloth or continue a futile dialogue once it is clear no reasonable accommodation exists.

F. Mixed Questions of Law and Fact

Whether a function is “essential” or an accommodation “reasonable” involves both factual and legal elements. Courts may:

• Submit these questions to a jury if facts are disputed; or
• Resolve them on summary judgment when the underlying facts are undisputed and only the legal conclusion remains in question.

In Bowles, both sides essentially agreed on the job’s duties and on what Bowles sought, so the court decided the issue as a matter of law.

VII. Impact and Implications

A. For Employers, Especially in the Service and Retail Sectors

The opinion provides several concrete lessons for employers:

1. Draft and maintain clear job descriptions:
   • Because 42 U.S.C. § 12111(8) gives evidentiary weight to written job descriptions, well‑crafted documents can be critical in later litigation;
   • Descriptions should accurately reflect multitasking and mobility requirements where those are essential.
2. Document actual practices:
   • Photos, training materials, and supervisor testimony that show how employees actually do the job can be decisive;
   • In Bowles, such evidence helped confirm that mobility and versatility were essential.
3. Evaluate accommodations carefully but efficiently:
   • Employers may request medical documentation and more detail when an initial request is vague;
   • They are not obligated to accept accommodations that would confine an employee to one duty if the job is fundamentally multi‑duty.
4. Interactive process obligations have limits:
   • If an employee’s only proposed accommodation is facially unreasonable, the employer’s failure to suggest alternatives will not, by itself, create liability;
   • Still, as a best practice, employers may wish to consider other options when feasible (e.g., different roles, modified schedules) even if not legally required, to reduce litigation risk and improve employee relations.

B. For Employees and Advocates

For employees and their counsel, the decision underscores:

1. Specificity is critical:
   • Requests like “I need to sit” are often insufficient;
   • Be prepared to specify how long you can stand, how often and how long you need to sit, and how these needs can be integrated into the job’s duties.
2. Align the accommodation with essential functions:
   • Early in a case, analyze the employer’s job description and actual practice;
   • Propose accommodations that allow performance of the job’s real essential functions, not just the title‑suggested duties.
3. Consider multiple, flexible accommodations:
   • A rigid formula (like 10 minutes standing / 5 minutes sitting) may be less defensible than accommodations that allow the employer to flexibly schedule breaks around workflow, so long as the medical needs are met;
   • Employees should be ready to discuss alternatives (e.g., shorter but more frequent micro‑breaks, rotation among tasks, reassignment to more stationary roles where available).
4. Litigation framing matters:
   • Because courts will compare the requested accommodation at summary judgment to that in the complaint, advocates must ensure that the complaint clearly and accurately describes the requested accommodation;
   • Do not rely on more generous or flexible accommodations described only later in briefing or testimony.

C. Litigation Strategy in ADA Cases

From a broader litigation standpoint, Bowles:

• Confirms that defendants can obtain summary judgment on reasonable‑accommodation claims when both the job’s essential functions and the proposed accommodation are undisputed and incompatible;
• Encourages plaintiffs to develop factual disputes about what the job actually entails if they wish to reach a jury;
• Signals that courts in the Sixth Circuit are willing to deem certain accommodations “facially unreasonable” in particular job contexts, especially those requiring continuous mobility and multitasking.

D. Implications for the Kentucky Civil Rights Act

Because the court again treated the KCRA as coextensive with the ADA in the disability context, Bowles becomes a significant precedent for Kentucky state‑law disability claims as well. Kentucky employers and courts are likely to follow the same reasoning in state‑court KCRA litigation.

VIII. Conclusion

Bowles v. SSRG II, LLC reinforces a central ADA principle: an accommodation is not reasonable if it would effectively remove or fundamentally alter essential job functions or require their reallocation to coworkers. In the setting of a fast‑paced, front‑of‑house restaurant position whose core duties require constant mobility and multitasking, a rigid requirement to sit for five minutes after every ten minutes of standing is facially unreasonable as a matter of law.

The decision also clarifies that:

• Vague requests like “sit when needed” do not suffice as accommodation requests;
• Employees are bound by the specific accommodations they plead and advocate;
• Interactive process claims cannot survive absent a viable, reasonable accommodation request.

As a published Sixth Circuit opinion, Bowles will shape future ADA and KCRA failure‑to‑accommodate litigation, particularly in the hospitality and retail sectors. It offers a detailed template for how courts will examine the interplay between essential functions, accommodation requests, and the limits of the interactive process — and thus serves as an important guide for employers, employees, and practitioners navigating disability accommodation disputes.