You must try more than once to accommodate an employee under the ADA, according to a decision from the Ninth Circuit Court of Appeals. In Humphrey v. Memorial Hospitals Association, Carolyn Humphrey filed a disability discrimination claim against her former employer, Memorial Hospitals Association (MHA). Humphrey consistently received excellent performance reviews working for MHA as a m​edical transcriptionist, but then began having attendance problems. She received two separate formal discipline notices from MHA.​

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