In a cautionary “tail” about the importance of engaging in the interactive process, when a Maryland automobile dealership allegedly denied an Iraq War veteran’s request for a service dog to manage panic attacks from post-traumatic stress disorder (PTSD), the U.S. Equal Employment Opportunity Commission (EEOC) filed suit on his behalf. According to the EEOC’s May 21, 2025, lawsuit, Criswell Chevrolet, Inc. violated the Americans with Disabilities Act (ADA) by denying an employee’s request for a service dog without ever engaging in the interactive process, essentially forcing the employee to quit. Approximately three months after the EEOC filed suit, the agency resolved the matter with Criswell via a consent decree that provided $30,000 for the former employee, mandated policy changes and training regarding the ADA and the interactive process, as well as two years of related monitoring via periodic compliance reporting to the EEOC.

Quick Hits

• An automotive dealership denied a disabled veteran’s request for a service animal without engaging in an interactive process.
• The EEOC brought suit, which resolved the matter through a two-year consent decree requiring the dealership to pay lost wages and considerable noneconomic damages to its former employee and being subjected to a host of compliance provisions and monitoring.
• Employers may consider reviewing and refreshing employees on the importance of the interactive process and accommodation procedures, especially when it comes to animal-based accommodation requests.

As set forth in its complaint, the EEOC alleged that Daniel Pulsipher, a parts stock clerk, requested and was denied a service dog. Pulsipher, a Navy veteran, suffered from traumatic brain injury and PTSD, which manifested through panic attacks triggered by sudden noises, individuals approaching from behind, flashing lights, and crowded areas. Roughly five months into his role at Criswell, Pulsipher received notice that he had been approved for a service dog to assist in managing his conditions. According to the EEOC’s complaint, Pulsipher made two requests to have the dog present with him at work, first to a member of his management team and then directly to Human Resources.

In response, Criswell allegedly denied his request in less than twenty-four hours, without any discussion, interactive process, or offer of alternative accommodations. Shortly thereafter, Pulsipher left his job with Criswell, citing continued unmitigated exposure to triggers. Through the consent decree, Pulsipher will receive back pay in the amount of $1,260, plus $28,740 in noneconomic damages. For its part, Criswell now finds itself on a short leash for the next two years, having to conduct training, report compliance, and be subjected to monitoring by the EEOC.

The Accommodation Process for Animal-Based Requests

Make no bones about it, accommodation requests for service animals or emotional support animals in the workplace are now fairly common after having been on the rise for years. While employers need not “roll over” on every such request, this case emphasizes the importance of recognizing their validity and putting such requests through a compliant, effective accommodation process, which necessarily includes robust interaction between the employer and the employee.

Critical to that accommodation process is recognizing the distinction between service animals that have been trained to perform a specific task and emotional support animals, which have not, but whose presence can still constitute a reasonable accommodation, depending on the circumstances and whether their presence is supported by valid medical documentation.

Additional accommodation process considerations employers may want to keep in mind are:

Sit—Sitting down with the employee and inquiring into what limitations the employee has in performing the essential functions of the position and to better understand how the proposed accommodation would work.

Speak—Speaking, not only with the employee, but with necessary human resource or management personnel to determine whether a service animal is feasible in that particular position, and if not, whether other effective accommodations may be available for the employee.

Heel—Walking through the accommodation process side by side with the employee to reach a resolution. Remember that the interactive process may require several rounds of discussion or clarifying medical information before establishing whether the accommodation or an alternate accommodation is effective and remains that way.

Fetch—Consider requiring the employee to obtain and return medical documentation, from a qualified provider, to validate the need for such an accommodation and/or to address whether other accommodations could be effective. Where a service animal is requested, it may also be reasonable to request the employee provide supporting documentation of the animal’s training and ability to provide the support at issue.

Stay—Staying vigilant and keeping in mind that when an accommodation is provided, it still warrants monitoring to make sure that it is still needed and continues to be effective and not unduly disruptive to the employer’s operations.

Next Steps

Employers may want to consider reviewing their current accommodation process, especially as it applies to animal-based requests, and provide refresher training to supervisors, management, and human resources personnel about the importance of recognizing and relaying requests for accommodation to the appropriate party, following the employer’s reasonable accommodation process, and continuing to engage in the interactive process to its conclusion.