Conners v. Wilkie, No. 19-2426 (7th Cir. 2021)
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In 2006 Conners began work as a licensed practical nurse (LPN) at a VA-operated facility near Chicago. Her duties included treating and observing patients, giving immunizations, managing the front desk, teaching classes, and completing paperwork. In 2011 she was hit by a car and suffered severe injuries. Her supervisor initially permitted her to retain her LPN position but radically reduced her responsibilities to only teaching and paperwork. After more than two years in that status, the VA concluded that Conners could not perform the essential duties of an LPN even with reasonable accommodations and unsuccessfully attempted to work with her on an acceptable reassignment. The VA terminated her employment.
Conners sued the VA under the Rehabilitation Act for failing to accommodate her disability, retaliating against her, and subjecting her to a hostile work environment based on her disability. The district court rejected the claims on summary judgment. Only the accommodation claim was appealed. The Seventh Circuit affirmed. Conners had to prove that when she was fired she was a “qualified individual with a disability,” capable of performing the essential functions of an LPN with or without reasonable accommodation. Conners’s abilities to stand and walk were severely limited, making it impossible for her to treat and observe patients, respond to medical emergencies, give immunizations, or manage the front desk
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