Bowles v. SSRG Holdings, LLC, 2:23-cv-00146

Tawna Bowles, who has severe arthritis, applied for a "restaurant team member" position at Chicken Salad Chick (CSC), operated by SSRG II, LLC.
Bowles notified CSC during her interview that she would need to sit intermittently due to her disability, and was initially told that this would not be an issue.
After being hired, CSC requested medical documentation substantiating her accommodation request. Bowles asked to sit for 5 minutes after every 10 minutes of standing.
CSC ultimately determined it could not accommodate this request, asserting that the "restaurant team member" position required constant mobility and a range of physical tasks that could not be completed with Bowles’ proposed accommodation.
Bowles filed suit under the ADA and Kentucky Civil Rights Act, alleging discrimination by failure to accommodate and failure to engage in the interactive process. The case reached the summary judgment stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Bowles' requested accommodation objectively reasonable?	Sitting for 5 out of every 15 minutes is reasonable, citing similar accommodations allowed and precedent.	The job requires extensive mobility; no similarly-situated employees had such an accommodation.	Accommodation not objectively reasonable for the position's essential duties.
Did CSC fail to accommodate Bowles under the ADA/KCRA?	CSC could have accommodated her by permitting more sitting, as other employers have done.	No feasible way to restructure job given the essential duties and physical demands; no precedent for such accommodation at CSC.	No failure to accommodate; Bowles not qualified for the role with her proposed accommodation.
Did CSC fail to engage in the interactive process?	CSC did not engage in sufficient dialogue after learning of her requirements.	Engagement stopped after finding accommodation unworkable for the position.	No standalone violation—no reasonable accommodation proposed.
Is summary judgment appropriate based on the evidence?	Factual disputes over reasonableness of accommodation should go to a jury.	No genuine dispute as to material facts; accommodation request not objectively reasonable.	Summary judgment for CSC granted; no issue suitable for trial.

Keith v. Cnty. of Oakland, 703 F.3d 918 (6th Cir. 2013) (outlining the elements and burdens in ADA failure-to-accommodate claims)
Kleiber v. Honda of Am. Mfg., Inc., 485 F.3d 862 (6th Cir. 2007) (establishing direct evidence standard for failure-to-accommodate claims)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard: must be genuine issue of material fact for trial)
US Airways, Inc. v. Barnett, 535 U.S. 391 (2002) (reasonableness of accommodations under ADA)