> But again, I'm talking out my butt on this. My point was not that medical necessity is a convincing case

I'm not a lawyer, or a manager, but I'm not quite convinced. I think OP should have that conversation with their doctor first. Claiming to need WFH to be safe is sounds related to some anti-Covid vaccination arguments. If the company cares about safety they are probably going to take reopening safely seriously, if they don't take Covid seriously they won't like accepting the initial request.

Though the eeoc does say having any WFH program makes it more likely it could be a reasonable accommodation. And I think my employer is already thinking about accommodations when reopening. Getting WFH might be a good possibility if their doctor agrees it's needed. https://www.eeoc.gov/laws/guidance/work-hometelework-reasona...