Sanchez v. Vilsack, No. 11-2118 (10th Cir. 2012)Annotate this Case
Plaintiff-Appellant Clarice Sanchez, a long-time secretarial employee of the United States Forest Service, suffered irreversible brain damage after falling at work. As a result of her injury, Sanchez lost the left half of her field of vision. She requested a hardship transfer to Albuquerque where she could better access ongoing medical treatment. After the Forest Service declined to accommodate her request, she brought suit under the Rehabilitation Act. The district court granted summary judgment in favor of the Forest Service, concluding that Plaintiff was not disabled within the meaning of the Act. Upon review, the Tenth Circuit disagreed and held that Plaintiff raised a genuine issue of material fact regarding her disability. On appeal, the Forest Service urged the Court to affirm summary judgment on an alternative ground. However, the Court declined, concluding that transfer accommodations for the purpose of medical treatment or therapy were not unreasonable per se.