Brunckhorst v. City of Oak Park Heights, No. 17-3238 (8th Cir. 2019)Annotate this Case
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the City in an employment discrimination suit under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA). The court held that plaintiff was not entitled to return to the Senior Accountant position because he did not return to work prior to the expiration of his Family Medical Leave Act (FMLA) leave; there was no medical reason why plaintiff needed to be reinstated to his former position; and thus he failed to show that returning to his original position was a reasonable accommodation.
The court also held that plaintiff's request that he be allowed to work from home was not a reasonable accommodation in light of his testimony that he could work at City Hall but that it "would have been easier" to work from home; plaintiff failed to make a facial showing that he could perform the essential functions of the job remotely; plaintiff failed to show that the City eliminated his position because of his disability or that the City terminated him because of his disability; there was no genuine issue of material fact that the City engaged in anything but a good-faith interactive dialogue; and his retaliation claim failed.