Last Updated on March 26, 2026 by MyHRConcierge

Employment decisions often involve balancing operational needs with employee requests. However, the recent case of Larkin v. Total Quality Logistics, LLC serves as a stark reminder that how employers handle accommodation requests- particularly those tied to medical conditions and pregnancy- can have profound legal and human consequences. For HR professionals and business leaders, this case underscores the importance of thoughtful, compliant, and compassionate decision-making.

Case Overview: What Happened

In Larkin v. Total Quality Logistics, LLC, the plaintiff, Chelsea Walsh, was an employee experiencing a medically documented high-risk pregnancy. On February 21, 2021- just four days after undergoing an operation on her cervix to prevent her going into early labor- Walsh requested a temporary work-from-home arrangement based on guidance from her healthcare provider, who recommended modified bed rest and remote work. 

The employer denied the request at the time, and on February 22, 2021, Walsh returned to work in-office. According to the claims presented, the company recommended Walsh take an unpaid leave of absence, instead. According to the lawsuit, Walsh continued to seek approval to work remotely. 

On February 24, 2021- the same day her remote work request was approved- Walsh gave birth to her daughter, Magnolia. Tragically, the child did not survive, and died approximately one hour and thirty minutes later. The plaintiff emphasized that the request was driven by timing and medical necessity- not personal preference. It was presented as a medically necessary accommodation that the employer failed to provide.

The jury ultimately accepted that position, finding that the delay in approving remote work was a substantial factor in the premature birth and subsequent death, supporting liability for wrongful death. The allocation of 90% fault to the employer suggests the jury viewed the workplace decision- not just the underlying medical risks- as the primary contributing factor.

The Legal Landscape: Pregnancy and Accommodation Obligations

This case sits at the intersection of several employment laws that HR teams must navigate carefully. Protections for pregnant employees have expanded in recent years, increasing employer obligations.

Under federal law, including the Pregnancy Discrimination Act, employers must treat pregnancy-related conditions the same as other medical conditions for purposes of accommodations. Additionally, the Americans with Disabilities Act may apply if a pregnancy-related complication rises to the level of a disability.

More recently, the Pregnant Workers Fairness Act has strengthened requirements by mandating reasonable accommodations for known limitations related to pregnancy, childbirth or related medical conditions- absent undue hardship. This includes temporary adjustments such as remote work, modified schedules, or reassignment of duties.

Where Employers Can Go Wrong

From an HR perspective, the risks in this case are not limited to the outcome; they stem from breakdowns in process. Common missteps include failing to engage in an interactive process, dismissing accommodation requests without proper evaluation or relying too heavily on rigid policies.

A blanket denial of remote work, for example, can be problematic if the role can reasonably be performed offsite or if exceptions have been made in other contexts. Consistency, documentation, and individualized assessment are critical.

Additionally, employers sometimes underestimate the importance of medical documentation and communication. When an employee presents a legitimate health concern, particularly one involving elevated risk, the expectation is not perfection—but a good-faith effort to explore viable solutions.

The HR Imperative: Building a Defensible Process

To mitigate risk and ensure compliance, HR teams should focus on strengthening their accommodation frameworks. This begins with training managers to recognize and properly escalate accommodation requests, especially those involving pregnancy or medical complications.

Employers should also formalize their interactive process. This means engaging in a documented dialogue with the employee, reviewing medical information where appropriate, and considering a range of potential accommodations. Even if a request is ultimately denied, the process itself must demonstrate reasonableness and care.

Clear policies are equally important, but they must allow for flexibility. A policy that categorically excludes remote work can create liability if exceptions are not considered when warranted.

A Call for Proactive HR Practices

The outcome of Larkin v. Total Quality Logistics, LLC is a powerful reminder that accommodation decisions can carry significant consequences. For employers, the takeaway is clear: proactive, compliant and compassionate HR practices are not just best practices… they are essential.

By strengthening processes, training leadership and fostering a culture of responsiveness and understanding, organizations can better protect both their employees and their business.

For more information on how to enhance your organization’s compliance efforts, contact MyHRConcierge at 855-538-6947 ext.108, ccooley@myhrconcierge.com. Or, schedule a convenient consultation below: