Unreported / Non-Citable
Background
Kelly Kjelstrom sued American Medical Response West over alleged workplace disability discrimination. Her claims included disability discrimination, failure to accommodate, failure to engage in the interactive process, and related theories under federal and California law.
AMR moved for summary judgment, arguing that the undisputed record showed it offered a reasonable accommodation and that Kjelstrom could not establish the essential elements of her remaining claims.
The Court’s Holding
The court granted AMR’s motion and entered judgment for the employer. It concluded that AMR had demonstrated the absence of a genuine dispute of material fact and that the accommodation it offered was reasonable on the evidentiary record.
Because an employer that offers a reasonable accommodation satisfies its core statutory obligation, Kjelstrom also could not show a failure to participate in the interactive process in good faith. The court likewise found the record insufficient to sustain her other discrimination theories and closed the case.
Key Takeaways
- An employee is entitled to a reasonable accommodation, not necessarily the employee’s preferred accommodation.
- A documented, effective offer can defeat both failure-to-accommodate and interactive-process claims.
- At summary judgment, the employee must identify admissible evidence creating a genuine factual dispute on each required element.
- California FEHA and federal ADA theories often rise or fall together when they depend on the same accommodation record.
Why It Matters
Employers should document proposed accommodations, the information exchanged, and the employee’s response. Employees and counsel should develop evidence explaining why an offered accommodation was ineffective or unreasonable; preference alone ordinarily will not carry the claim past summary judgment.