Alisha Strife, a disabled Army veteran diagnosed with PTSD and other service-related injuries, worked for Aldine Independent School District (AISD) in Texas. After years of successful employment and promotion, her disabilities led her to request a workplace accommodation in 2022—permission to bring her certified service dog, Inde, to assist with physical stability and PTSD symptoms. While she provided documentation from her treating providers, AISD requested further evaluation. Strife, through legal counsel, argued that AISD’s handling of her request violated the Americans with Disabilities Act (ADA), and she filed a Charge of Discrimination in January 2023.
In February 2023, Strife filed a federal lawsuit alleging failure to accommodate, discrimination, retaliation, hostile work environment, and ADA interference. Though AISD eventually granted her request to bring the service dog after being informed that alternatives like a cane or walker were inadequate, the district moved to dismiss her claims. On June 12, 2024, the court sided with AISD, dismissing Strife’s failure-to-accommodate and hostile work environment claims and granting summary judgment on the remaining allegations. Strife then appealed the decision to the Fifth Circuit.
Strife alleges that AISD’s six-month delay in granting her request to bring a service dog to work constituted a failure to reasonably accommodate her disability under the ADA. While the first two elements of her claim—that she is a qualified individual with a disability and that AISD was aware of her limitations—are uncontested, the dispute centers on whether the delay itself amounted to a failure to accommodate.
The law requires both employer and employee to engage in a good-faith, interactive process to identify appropriate accommodations, and courts have recognized that unnecessary or obstructive delays can signal a lack of good faith. Strife alleged that AISD deliberately delayed the process by demanding an independent medical exam. She also claimed that AISD failed to offer alternative accommodations and only approved her request after legal action was initiated—facts that, if true, could support a finding of ADA violation. The appellate court determined that Strife’s allegations were sufficient to plausibly claim AISD did not act in good faith and may have failed to provide reasonable accommodation.
Strife challenged the dismissal of her hostile work environment claim, which required her to allege severe or pervasive disability-based harassment affecting her work conditions. She asserted that AISD’s six-month delay and request for a medical exam amounted to harassment. However, the court found these actions insufficient to meet the legal standard for a hostile environment, ruling that procedural delays and disputes over accommodation do not constitute harassment under the ADA.
Strife also challenged the summary judgment ruling on her disability discrimination claim, which requires proof of a disability, job qualification, and an adverse employment action due to the disability. Her first argument—that the six-month delay in processing her accommodation constituted discrimination—failed because she maintained her job, pay, and performance level during that time, with no more than minimal inconvenience. Her second argument—that requiring an independent medical exam was discriminatory—also failed, as the exam never occurred and had no impact on her employment conditions, leading the court to uphold summary judgment against her.
Strife then argued that AISD retaliated against her for requesting accommodations by delaying its decision and requesting an independent medical exam. However, the court found AISD had a legitimate, non-retaliatory reason for the exam—to assess whether alternative accommodations were available—since Strife’s submitted documentation didn’t address that issue. Because Strife failed to show this rationale was a pretext for retaliation, the district court properly granted summary judgment on her retaliation claim.
Finally, Strife claimed that AISD violated the ADA’s anti-interference provision, but she failed to provide specific evidence showing how the district interfered with her rights. The court found that AISD’s actions were part of a lawful interactive process to assess her accommodation request and were not motivated by discrimination. As a result, the district court properly granted summary judgment on the ADA interference claim.
The appeals court affirmed dismissal of all claims, except the claim concerning the delay in granting her request for an accommodation.
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