Case Explained: Christine Klimek v. CentraCare Health System

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-06-15 The eighth-circuit reversed the district court’s grant of summary judgment in favor of the defendant, holding that genuine issues of material fact precluded a ruling as a matter of law on the plaintiff’s claims under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act. The court applied the *McDonnell Douglas* burden-shifting framework to evaluate whether the plaintiff was a “qualified individual” entitled to reasonable accommodation for her disability, Complex Regional Pain Syndrome (RSD). The court reasoned that an employer’s assertion that compliance with a vaccination policy is an “essential job function” does not automatically satisfy the ADA definition, as an accommodation cannot simultaneously be an essential function. Viewing the evidence in the light most favorable to the plaintiff, the court found sufficient dispute regarding whether in-person patient care was an essential function of her remote clinical documentation role, noting her job description and actual work history involved no physical patient contact. Furthermore, the court determined that a jury could find the employer failed to engage in the required interactive process because it denied accommodation requests without explanation, refused to consider the plaintiff’s existing remote work arrangement as a viable accommodation, and offered only vaccination or termination rather than exploring alternatives like continued remote work. The court also rejected the employer’s undue hardship defense, finding its arguments based on hypothetical scenarios rather than specific evidence of actual hardship. The practical consequence is that the case is remanded to the district court for further proceedings, allowing the plaintiff’s discrimination and failure-to-accommodate claims to proceed to trial where a jury will resolve the disputed factual issues regarding her disability status, job qualifications, and the reasonableness of the employer’s actions. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.