ADA: Termination Permissible Given Nurse’s Inability to Perform Essential Functions—With or Without Reasonable Accommodation

​In an unpublished opinion, the U.S. Court of Appeals for the 6th Circuit held that a nonprofit health plan did not violate the Americans with Disabilities Act (ADA) when the organization terminated a registered nurse (RN) who was unable to perform essential functions of her job, with or without a reasonable accommodation.

The nurse had rheumatoid arthritis, characterized by acute "flares" of symptoms that resulted in intermittent difficulty with walking, lifting heavy items, and driving, as well as increased susceptibility to illness due to a weakened immune system. She worked from home as a case manager for the defendant health plan for four years, at which time her position—and all equivalent positions—were eliminated in an organizational change. The positions were replaced with "high-risk case manager" positions, which required driving to conduct client visits. Although high-risk case managers could delegate some visits to social workers and patient navigators, nurses...