Beverly J. Rauen v. United States Tobacco Manufacturing Limited Partnership
319 F.3d 891, 13 Am. Disabilities Cas. (BNA) 1797, 2003 U.S. App. LEXIS 2211 (2003)
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Rule of Law:
An employer is generally not required under the Americans with Disabilities Act (ADA) to provide a work-from-home arrangement as a reasonable accommodation, particularly when the employee can perform all essential job functions without it and the job requires on-site presence, teamwork, and interaction.
Facts:
- Beverly Rauen began working for United States Tobacco (UST) in 1968 and eventually became a software engineer whose duties involved managing on-site projects and monitoring contractors at UST's facility.
- In 1996 and 1998, Rauen was diagnosed with and treated for cancer, resulting in permanent health conditions that caused extreme fatigue and required frequent restroom use.
- Upon returning to work in January 1999, Rauen presented a doctor's note and requested to work from a home office as an accommodation for her disability.
- In a May 1999 meeting, Rauen demanded a "home office in its entirety," stating she would determine when her physical presence at the plant was necessary.
- During the meeting, Rauen rejected UST's alternative accommodation suggestions, including a partial home-office schedule, private facilities at work, or a designated place to rest.
- Despite not receiving the requested accommodation, Rauen continued to work full-time at the UST facility from January 1999 through October 2001 and performed all essential functions of her job exceedingly well.
Procedural Posture:
- In August 1999, Beverly Rauen filed a charge of disability discrimination against United States Tobacco (UST) with the EEOC.
- On October 25, 1999, Rauen filed a lawsuit in federal district court, alleging UST violated the ADA by failing to provide a reasonable accommodation.
- UST moved for summary judgment.
- The district court granted UST's motion for summary judgment, finding that Rauen was not entitled to an accommodation because she could perform the essential functions of her job without one.
- Rauen (appellant) appealed the district court's decision to the United States Court of Appeals for the Seventh Circuit.
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Issue:
Does an employer violate the Americans with Disabilities Act by denying an employee's request for a full-time, self-regulated work-from-home accommodation when the employee is capable of performing all essential job functions without any accommodation and the job's duties require on-site presence?
Opinions:
Majority - Kanne, Circuit Judge.
No, an employer does not violate the ADA by denying such a request. The court held that a work-from-home arrangement is rarely a reasonable accommodation, and an employee's ability to perform the job's essential functions without any accommodation weighs heavily against the reasonableness of the requested accommodation. The court reasoned that, based on precedent like Vande Zande v. Wis. Dep’t of Admin., most jobs require teamwork, interaction, and supervision that cannot be effectively performed from home. Rauen’s job, which involved monitoring on-site contractors and managing plant projects, was not the 'extraordinary case' where a home office would be reasonable. Furthermore, the court found Rauen's specific demand—a 'home office in its entirety' where she alone would determine her schedule—was unreasonable on its face. The court concluded that while an employee's ability to perform their duties without help doesn't automatically disqualify them from any accommodation, it makes it significantly more difficult to prove that a major accommodation like a home office is reasonable.
Analysis:
This decision reinforces the high threshold for employees seeking a work-from-home accommodation under the ADA, establishing it as an exceptional rather than a routine option. It clarifies that an employee's demonstrated ability to perform essential job functions without an accommodation is a powerful factor weighing against the reasonableness of their request. This precedent provides employers with a strong basis for denying open-ended, employee-controlled remote work requests, particularly for roles that inherently require on-site collaboration, supervision, or physical presence. The ruling distinguishes between accommodations that enable an employee to perform their job and those that merely make it more convenient, suggesting the ADA's focus is on the former.
