California, United States of America
The following excerpt is from Nealy v. City of Santa Monica, 184 Cal.Rptr.3d 9, 234 Cal.App.4th 359 (Cal. App. 2015):
But protected activity does not include a mere request for reasonable accommodation. (Rope v. AutoChlor System of Washington, Inc. (2013) 220 Cal.App.4th 635, 652, 163 Cal.Rptr.3d 392
[184 Cal.Rptr.3d 26]
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