Courts Reject Her Claim
U.S. District Judge Richard D. Bennett ruled in April 2024 that Johns Hopkins was not at fault for failing to accommodate Tarquinio, finding that she caused the breakdown of the interactive process by refusing to cooperate.
While the Fourth Circuit criticized the district court for simplifying the blame, the appellate panel nonetheless sided with the university, noting that Tarquinio had provided only vague references to immune issues without explaining how they made vaccination unsafe.
“Faced with Tarquinio’s unusual medical profile, the lab had the right to ask for more objective evidence,” the panel wrote. “Because she prevented the lab from learning why her condition required the accommodations she asked for, she cannot show that the lab had a duty to accommodate.”
A Fight Over ADA Interpretation
In her petition to the Supreme Court, Tarquinio argued that the lower courts had eroded ADA protections by allowing employers to lean on CDC vaccination guidelines instead of conducting an individualized assessment of each worker’s medical situation.
She contended that the ADA’s framework “prevents employers from second-guessing doctors’ treatment plans” and that her case was a prime opportunity for the Court to reaffirm the ADA’s individualized protections.
However, Johns Hopkins declined to respond to her petition, and the justices refused to take up the case.
