Six Months, One Service Dog, and a Big ADA Warning for Employers
The Fifth Circuit’s recent decision in Strife v. Aldine Independent School District is a powerful reminder that an employer’s obligation under the ADA isn’t just about the outcome of an accommodation request. It’s also about the process—and whether the employer engages in that process in good faith.
This case centers on a veteran, a service dog, and a six‑month delay that the court said may itself constitute a failure to accommodate.
Let’s walk through what happened.
A Veteran with Documented Disabilities—and a Strong Track Record
Strife served her country and sustained significant injuries: shoulder, leg, and brain trauma, followed by a diagnosis of PTSD. The VA later classified her as:
100% disabled due to service‑related PTSD and depression; and
Partially disabled due to knee and ankle injuries.
Her disabilities weren’t manageable through alternative treatments, so she obtained a certified service dog trained to help her maintain balance, prevent falls, and mitigate PTSD symptoms.
Despite these challenges, Strife excelled. She joined Aldine ISD in 2012 as a teacher, transitioned to a Testing Coordinator role in 2015 when classroom teaching became untenable, and after six years of strong performance, was promoted to Human Resources in 2021.
The Accommodation Request—and the Six‑Month Runaround
In 2022, Strife requested a straightforward accommodation: allow her service dog to accompany her at work.
What followed was a six‑month odyssey.
1. The school district asks for more information.
They wanted to know which job functions were impacted and whether alternatives existed.
2. Strife provides a letter from her VA provider.
The letter described the dog as “invaluable” to her mental and physical recovery.
The district rejected it because the provider was a doctor of pharmacy, not a board‑certified physician.
3. Strife provides a letter from her treating psychiatrist.
Same conclusion: the dog is necessary.
4. The district sends a questionnaire.
The psychiatrist again confirms the accommodation needed: the support of a service animal.
5. The district demands an independent medical exam.
At this point—nearly three months in—Strife hires a lawyer.
6. Counsel provides three additional letters.
Two more physicians confirm her limitations and urge approval.
She also files an EEOC charge and undergoes a VA exam, which reaches the same conclusions.
7. The district still resists.
They claim the VA evaluation is insufficient without the doctor’s notes.
Counsel provides the notes.
The district then says the notes fail to identify “alternative accommodations.”
8. A court orders the district to complete the interactive process.
Only then does the district approve the request for a service dog.
All told, the process took six months. Strife did not suffer a new physical injury during that time—but she did work under “suboptimal conditions,” as the Fifth Circuit later put it.
The Legal Question: Can Delay Alone Be a Failure to Accommodate?
The district court said no.
The Fifth Circuit said: not so fast.
The Fifth Circuit said the lower court focused on the wrong things:
Strife didn’t suffer a new injury
She was already disabled before the request
Her job duties didn’t change during the delay
But the Fifth Circuit reframed the analysis.
The real question is this: Did the employer fail to make reasonable accommodations after being informed of the employee’s limitations?
And importantly:
Reasonable accommodations aren’t limited to enabling essential job functions;
Employers shouldn’t force employees to work in pain or under avoidable hardship when an accommodation could alleviate it; and
Delay can create liability when it reflects a lack of good faith.
The court noted several red flags:
The district repeatedly questioned documentation that was consistent and medically supported.
The independent exam request came after months of back‑and‑forth, despite the district already having sufficient information.
The district offered no alternative accommodations—undermining its claim that it was considering them.
The request was granted only after litigation pressure and a looming injunction hearing.
Given these facts, the Fifth Circuit held that Strife had plausibly alleged a failure to accommodate and remanded the claim.
What Employers Need to Take Away
This case is a masterclass in what not to do during the ADA interactive process. The court’s focus was clear: good faith matters.
Here’s what this means for HR leaders:
1. A delay can be discriminatory—even if the employee isn’t physically harmed.
The absence of injury does not absolve the employer.
2. Granting the accommodation eventually does not erase a bad‑faith process.
The process itself is part of the obligation.
3. If you need more information, ask—but don’t keep moving the goalposts.
Repeated, shifting demands look like obstruction, not diligence.
4. Consider interim accommodations.
If the process is taking time, don’t leave the employee in limbo.
5. Legal counsel is the guardrail.
Management may not prioritize the interactive process.
Your legal counsel can be the one who keeps it moving and keeps it compliant.
Bottom Line
Strife v. Aldine ISD is a reminder that the ADA isn’t just about the final decision—it’s about the employer’s conduct throughout the process. When an employee is getting the runaround, courts notice.
Good faith isn’t a box to check.
It’s the heart of the interactive process.