As Minnesota’s cabin season kicks into high gear, employers may find themselves fielding a familiar request: “Can I work remotely?” For many employees, the ask is simply a lifestyle preference—a desire to swap the office for a deck overlooking the water. But for others, the request may be rooted in a medical condition that makes commuting or working on-site difficult. With respect to the latter, employers need to recognize that what sounds like a casual summer plan may actually be a request for a reasonable accommodation under disability discrimination law.
Remote Work as a Reasonable Accommodation
Under both the Americans with Disabilities Act and the Minnesota Human Rights Act (“MHRA”), employers have an obligation to provide reasonable accommodations to qualified employees with disabilities, unless doing so would impose an undue hardship. Remote work has long been recognized as a potential reasonable accommodation, particularly where an employee’s essential job functions can be performed from a location other than the employer’s premises.
The question is rarely whether remote work can be an accommodation—it is whether it is reasonable under the circumstances. Factors such as the nature of the job, the employer’s operational needs, and the employee’s specific limitations all play a role. An employee whose disability makes a daily commute painful or medically inadvisable, for example, may be entitled to work remotely—even if the rest of the team is expected to be on-site. The fact that the employee happens to be working from a cabin on Gull Lake rather than a home office in the suburbs does not, by itself, change the analysis.
Minnesota’s New Interactive Process Requirements
Employers in Minnesota should pay particular attention to recent amendments to the MHRA, which now impose more specific obligations around the interactive process. Under the amended statute, when an employee requests an accommodation—or when the employer has reason to know that one may be needed—the employer must engage in a timely, good-faith interactive process to identify an effective accommodation. Although for some managers and supervisors, it feels like it should change the analysis.
The amendments clarify that the interactive process is not optional and is not merely a best practice. It is a legal obligation. An employer that simply denies a remote work request without engaging in the back-and-forth required by the statute risks liability, even if a legitimate business reason for the denial exists. The law expects a dialogue, not a unilateral decision.
This is particularly relevant in the summer remote work context. An employee who says, “I’d like to work from the cabin this summer because my chronic pain flares up with the commute,” has arguably put the employer on notice that an accommodation may be needed. The employer cannot simply say “no” and move on. Instead, it must explore the request, discuss alternatives and genuinely evaluate the request.
Practical Tips for Employers
As the summer months approach and accommodation requests arrive—whether framed casually or formally—employers should keep the following principles in mind.
First, treat any request that references a medical condition or limitation as a potential accommodation request, regardless of how it is worded. Employees are not required to use magic words like “reasonable accommodation” or “ADA” to trigger an employer’s obligations.
Second, engage in the interactive process promptly and in good faith. Ask questions, request supporting medical documentation where appropriate, and explore whether remote work—or some hybrid arrangement—would allow the employee to perform the essential functions of the job.
Third, evaluate the request on its merits. The fact that an employee wants to work from a vacation property does not make the request frivolous. If the employee has a qualifying disability and can perform the essential functions of the job remotely, the location of the remote workspace is generally not the employer’s concern—so long as the employee remains available, productive, and in compliance with any applicable policies regarding data security, responsiveness, and work hours.
Fourth, push back when appropriate. Depending on the circumstances, the employer may have opportunities to collect information about the accommodation request (including medical documentation) and explore the medical necessity of the request. But this must be done carefully so as to not unintentionally create legal risk.
Conclusion
It is beyond question that summer at the cabin is a Minnesota tradition. For some employees, working remotely during the warmer months is a matter of convenience; for others, it is a matter of medical necessity. Employers who fail to distinguish between the two—or who dismiss accommodation requests without engaging in the interactive process now required under the MHRA—expose themselves to legal risk. The best approach is a familiar one: listen, engage, and make individualized assessments grounded in the specific facts of each situation. As always, reach out to our team if you have questions or need advice and counsel relating to these issues.