Navigating the Legal Complexities of Remote and Hybrid Workforces: Lessons from Mobley vs. St. Luke’s Health System

Adopting remote and hybrid work models has become increasingly common, especially after the global pandemic. While these arrangements offer flexibility and other benefits, they also present unique legal challenges that employers must be prepared to handle. Understanding and addressing these issues proactively is key to avoiding complications and ensuring a smooth operation. The case of Joseph Mobley vs. St. Luke’s Health System, Inc. serves as an instructive example in this regard.

Background of the Case

In this landmark case, Joseph Mobley, an employee diagnosed with multiple sclerosis, requested accommodations to telecommute during flare-ups of his condition. St. Luke’s Health System, his employer, denied these requests, leading to a lawsuit under the Americans with Disabilities Act (ADA) and the Missouri Human Rights Act (MHRA). In this case, the Eighth Circuit Court’s decision offers several critical takeaways for employers managing remote or hybrid workforces.

Key Takeaways for Employers

  1. Challenges in Denying ADA Accommodations for Additional Telework: If you already offer a hybrid schedule that includes telework, denying an ADA accommodation request for additional telework may be challenging. In Mobley’s case, the court scrutinized the employer’s refusal to provide additional telework as an accommodation, even though some level of telework was already part of the job. This implies that employers should carefully consider and justify any refusal of additional telework accommodations under the ADA.
  2. Documenting the Essential Nature of Onsite Work: In cases where telework is denied on the basis that onsite work is essential, it’s crucial to document the specific reasons why onsite presence is necessary. This documentation should detail how certain tasks or responsibilities require physical presence in the workplace. In Mobley’s situation, the court examined whether he could perform his job’s essential functions through his proposed accommodation of teleworking during MS flare-ups.
  3. Incorporating Essential Job Functions in Job Descriptions: Planning ahead by clearly documenting the essential nature of onsite work in job descriptions can be invaluable. This not only sets clear expectations for prospective and current employees but also provides a solid foundation for decision-making regarding accommodation.
  4. Managing Provisional Telework Accommodation: If an employer provides provisional telework accommodation, it’s important to document that this arrangement is temporary and may involve excusing some essential job functions. Moreover, this context should be clearly communicated in performance reviews to avoid misunderstandings or disputes.
  5. Engaging in Good Faith in the Interactive Process: The Mobley case underscores the importance of engaging in good faith in the interactive process when considering accommodation requests. Employers should document their efforts to work with employees in finding suitable accommodation and be prepared to demonstrate these efforts if challenged.


The Mobley vs. St. Luke’s Health System case serves as an example of the complexities and legal nuances in managing remote and hybrid workforces, particularly in the context of ADA accommodations. As organizations navigate these uncharted waters, it is essential to approach telework policies and accommodation requests with a comprehensive understanding of legal obligations and practical considerations. Proactively addressing these issues, thoroughly documenting decisions and processes, and engaging constructively with employees are critical steps in minimizing legal risks.

However, navigating these legal intricacies can be challenging, especially for businesses without a dedicated legal department. This is where outsourcing legal service becomes invaluable. Hiring a firm like Catalyst Legal provides expertise in navigating the complexities of employment law in remote and hybrid work settings. We can help you develop compliant policies, handle accommodation requests effectively, and ensure that all employment practices adhere to current legal standards.


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