Case Explained: Non-Argument Calendar WILL TWIGG v. PALM BEACH COUNTY SHERIFF’S OFFICE

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-01 Docket: 9:23-cv-81352-DMM The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of the Palm Beach County Sheriff’s Office, upholding the dismissal of Will Twigg’s claims under the Americans with Disabilities Act (ADA), the Family and Medical Leave Act (FMLA), and the Uniformed Services Employment and Reemployment Rights Act (USERRA). The court held that Twigg failed to establish a prima facie case under the ADA because he was not a “qualified individual” capable of performing the essential functions of his position as a Corrections Deputy Sheriff. The court applied the standard that an accommodation is reasonable only if it enables the employee to perform essential job duties, and employers are not required to eliminate such duties or create new positions. The opinion determined that responding to violent or emergency situations was an essential function of the role, which Twigg’s PTSD prevented him from performing even with accommodations. Furthermore, Twigg failed to identify a specific vacant position for reassignment and had not maintained his required Florida Department of Law Enforcement certification, another essential function. Regarding the FMLA claim, the court ruled that an employee has no right to reinstatement if they cannot perform the essential functions of their original or equivalent position. For the USERRA claim, the court found no evidence that Twigg’s military service was a motivating factor in his termination, noting that the Sheriff’s Office provided legitimate, non-discriminatory reasons for the discharge related to his lack of certification and inability to perform job duties. Additionally, the appellate court affirmed the district court’s procedural rulings, finding no abuse of discretion in denying Twigg’s Rule 59(e) motion to alter the judgment, its denial of a request to modify the scheduling order due to Twigg’s lack of diligence during discovery, and its grant of a protective order preventing the deposition of Sheriff Bradshaw, who was found to have minimal involvement in the termination decision. The practical consequence is that the summary judgment in favor of the employer stands final, and Twigg’s appeal is dismissed with no further relief granted. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.