A recent case, Yanick v. Kroger Company, is useful to discuss and explain how an employee should request a reasonable accommodation for a protected disability.
Yanick was the bakery department manager at a Kroger in Michigan. She was a long-term employee that had done a good job for Kroger, according to her performance evaluations. She required treatment for cancer, was off for a while on account of that treatment, and returned to work. A new store manager, Schnepp, took over the same week that Yanick was diagnosed with cancer. Before Yanick took off for her cancer treatment Schnepp expressed dissatisfaction to Yanick about the bakery.
When Yanick returned to work after cancer treatment and a few months absence, Schnepp again got after her. According to the Sixth Circuit's (the federal appeals court that covers Kentucky) opinion, Yanick told Schnepp that she "was struggling and needed some time to get back to normal." Yanick also told Schnepp that she had been very physically taxed by working some 53 hours on her first week back from medical leave. Yanick apparently felt forced out by Schnepp and stepped down to a lower-paying job at a different location.
Yanick filed suit claiming that Kroger had failed to reasonably accommodate her disability, among other things. The court's analysis of whether/how Yanick had requested a reasonable accommodation is important and these were the court's key points:
there is no bright-line rule for determining whether an employee requested an accommodation
employees need not use words like “accommodation” or “disability”
the general assessment is whether the employee communicated a need for an adjustment at work because of a disability. Context matters in this assessment and employers must draw reasonable inferences from what an employee says, bearing in mind the statements’ context.
The court concluded that Yanick had requested a reasonable accommodation. Yanick's statements that she was struggling, needed more time to get back to normal and had been physically taxed by the high number of hours she'd worked One could reasonably understand these comments as a request for a reduced work schedule.