On April 29, 2025, in Fisher v. City of Lansing, the U.S. District Court for the Western District of Michigan ruled that the City of Lansing did not fail to accommodate an employee’s request to bring an emotional support dog to work. The court found that the proposed accommodation failed to address a key obstacle that prevented the employee from performing an essential job function.

This decision has broad implications for employers facing an increase in accommodation requests related to mental health conditions and the presence of service or emotional support animals in the workplace.

Quick Hits

• Under the Americans with Disabilities Act (ADA), an employee must propose a reasonable and necessary accommodation that addresses a key obstacle that prevents the employee from performing a necessary function of the position.
• The ADA does not include emotional support animals in its definition of “service animals.”
• Where an employee admits he or she can perform the essential job functions without the requested accommodation, even if not optimally, it weakens any claim that the accommodation is necessary.

Background

Aaron Fisher, a firefighter for the City of Lansing, Michigan, suffers from post-traumatic stress disorder (PTSD). Fisher requested permission to bring a service dog to work, stating that his symptoms worsened while on emergency calls. Although the City of Lansing required employees to submit a reasonable accommodation request form with medical documentation to Human Resources (HR), Fisher bypassed this policy. Fisher submitted his request only to his battalion chief, who initially approved it. However, HR denied the request after discovering the arrangement and determining that Fisher had provided insufficient documentation.

Fisher later submitted another request, this time including a letter from his physician stating he needed an “emotional support animal during work hours.” The city again denied the request. Fisher responded by filing a lawsuit under the ADA and Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), claiming discrimination and retaliation.

In its motion for summary judgment, the city argued Fisher did not need a service dog to perform his essential job functions. The City of Lansing also contended that the presence of a dog could hinder Fisher’s ability to respond quickly to emergencies, that the dog might not always remain under Fisher’s control, and Fisher had not demonstrated a medical necessity for the accommodation.

The Court’s Decision

The court granted summary judgment in the city’s favor, holding that Fisher had not shown that a service dog was necessary for him to perform his essential job function. Fisher’s own testimony indicated he could perform his duties—though not optimally—without the dog. Additionally, the letter from Fisher’s psychologist recommended an emotional support animal but did not state that he could not perform his job without it. While the court did not decide whether Fisher’s dog qualified as a “service animal” under the ADA, it pointed out that the ADA authorizes “service animals” but not “emotional support animals.”

The court also observed that Fisher received a positive performance evaluation and had accrued substantial sick leave and overtime hours after the city denied his accommodation request. These facts supported the conclusion that Fisher could perform his job without the accommodation. Ultimately, the court found Fisher had not met his to prove the dog was a necessary accommodation and dismissed the case.

Key Takeaways for Employers

This case highlights several important considerations for handling ADA accommodation requests:

• Under EEOC guidance, employers may require employees to provide adequate medical documentation to support accommodation requests and follow a consistent formal review process if the “requirements are job related and necessary for the conduct of the business.”
• Distinguishing between service animals and emotional support animals can be useful. ADA regulations authorize accommodations related to service animals, but not emotional support animals.
• Assessing whether the accommodation is necessary for the employee to perform essential job functions is valuable. If the employee can perform those duties without the accommodation, it may not be required.
• Employers may also want to communicate clearly with employees about the status of their accommodation requests and provide documented explanations for any denial.

Employers that consider these factors may be more able to effectively manage accommodation requests and remain compliant with the ADA.