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September 24, 2025
In a recent decision, the U.S. Court of Appeals for the Fourth Circuit affirmed the dismissal of an employee’s failure-to-accommodate claim because the employee refused her employer’s attempt to understand the limitations stemming from her condition. See Tarquinio v. Johns Hopkins University Applied Physics Lab, No. 24-1432 (June 25, 2025).
Factual Background
In the second year of the COVID-19 pandemic, then-President Biden issued an Order requiring all federal contractors to comply with guidance issued by the Safer Federal Workforce Task Force, which required all federal contractors to be vaccinated against COVID-19. In response, Johns Hopkins University Applied Physics Lab (the Lab), a federal contractor, directed its employees to be vaccinated.
Sally Tarquinio, who worked for the Lab as a systems engineer, suffers from “chronic Lyme disease,” which produced “Lyme-induced immune dysregulation.” She asked for a medical exemption from the vaccination mandate to accommodate her disability. Tarquinio based her exemption request on two medical documents, one blood test from 2012 that showed that she had Lyme disease at the time of the test, as well as a form signed by her health care provider that named “chronic Lyme disease [and] Lyme induced immune dysregulation” as the basis for her request.
Because it was unclear to the Lab why Tarquinio’s condition prevented her from being vaccinated (Lyme disease is not a medical contraindication for COVID-19 vaccination), the Lab asked for Tarquinio’s consent to speak to her doctors. Tarquinio declined to provide such consent and simply expressed her fear that, if she were to be vaccinated, her “body [would] go crazy due to immune chaos, and most likely [suffer] a bad outcome.” She offered to take (and pay for herself) a weekly CDC-approved saliva COVID-19 test and work on-site two to five days per week and at home on the other days.
In response, the Lab sought updated medical documentation, including why the COVID-19 vaccine is a concern due to her medical condition. Tarquinio failed to provide updated medical documentation. The Lab followed up a few days later but, again, Tarquinio refused to provide any other medical records.
Thus, the Lab denied Tarquinio’s accommodation request and ultimately terminated her employment because she was neither vaccinated nor had an exemption from the vaccination mandate.
Tarquinio sued and claimed that the Lab failed to accommodate her disability; terminated her employment her because of her disability; and subjected her to an unlawful medical examination. The district court dismissed all three claims before trial. Tarquinio appealed.
Relevant Law
Under the Americans with Disabilities Act (ADA), liability for a failure-to-accommodate claim is imposed on employers who do not make reasonable accommodations for known limitations. The ADA requires an employer and the employee seeking an accommodation to engage in an interactive process – a good faith dialogue to identify a reasonable accommodation. That process “should identify the precise limitations resulting from the disability and potential reasonable accommodations that could overcome those limitations.” 29 C.F.R. § 1630.2(o)(3).
The District Court Dismissed Tarquinio’s Claims
The district court dismissed Tarquinio’s claims because it found that she was responsible for a breakdown in the interactive process. Specifically, the district court held that, when Tarquinio declined to sign a medical release form, she refused to participate in the interactive process, foreclosing liability against the Lab. Though the Fourth Circuit agreed with the district court’s dismissal of Tarquinio’s claims, it used this case to clarify what the interactive process is and what it does.
The Fourth Circuit Affirms the Dismissal of Tarquinio’s Claims
The Fourth Circuit highlighted the fact that the ADA requires an employer to accommodate an employee’s known limitations, not their known disabilities. The Lab did not dispute Tarquinio’s assertion that she had Lyme disease; it disputed how that condition limited her in such a way that she could not comply with the vaccination mandate. The interactive process would have allowed the Lab to explore whether a need for accommodation existed. Had the Lab known about Tarquinio’s limitations and failed to accommodate them, it could have been liable under the ADA. But Tarquinio refused to allow the Lab to explore her alleged limitations. Thus, the Lab’s duty to accommodate never arose, and no liability exists.
Employer Takeaways
As the Fourth Circuit pointed out, the ADA’s interactive process is a means, not an end. Neither an employer nor an employee simply can rest on a breakdown in the interactive process without connecting that breakdown to an element of liability. But if an employee prevents you from understanding the limitations stemming from a disability, then your duty to accommodate never arises. And when a disability and its limitations are not obvious, you have a right to seek medical documentation. If an employee prevents you from understanding why a condition requires an accommodation, the employee’s failure-to-accommodate claim likely will fail.
*Special thanks to Lydia Deardoff, our Pre-Law Intern, for her contributions to this article.
This article is designed to provide one perspective regarding recent legal developments, and is not intended to serve as legal advice. Always consult an attorney with specific legal issues.
