A recent ADA case in the U.S. District Court of Hawaii serves as a reminder that employees do not have to use any specific language to request a reasonable accommodation and that employers should follow up with employees in order to satisfy their duty to engage in the interactive process required by law. After having an angry outburst for which he received a final written warning, the plaintiff began to bring his small Shih Tzu, Sugar Bear, to work with him without permission.  According to the plaintiff, who was diagnosed with ulcerative colitis and depression, he told his employer's Human Resources personnel that he had a service animal card for Sugar Bear, that having the dog present helped with his “anger issues,” and that he was in the process of obtaining paperwork to support his need for the animal at work.  Plaintiff never provided the paperwork, claiming he was under the impression that he could not bring the dog to work anymore.  About six months later, the plaintiff had another loud argument with a subordinate, and the company fired him for the inappropriate conduct.  Plaintiff sued his employer for disability discrimination under the Americans with Disabilities Act (ADA), including a claim that the employer failed to reasonably accommodate his disability.  In denying the employer’s Motion for Summary Judgment, the court allowed plaintiff’s disability discrimination and failure to accommodate claims to proceed to trial because there were questons of fact regarding whether or not the employer should have followed up with the employee once he placed it on notice that he may need an accommodation for a health-related issue.  Employers should be aware that the ADA requires no magic words to notify the company of a disability and/or request for accommodation, and accommodations may come in all different forms.