7th Circuit rejects manager’s work-from-home accommodation request

During the COVID-19 pandemic, many employees were required to work from home. Did that collective experience rewrite the rules for employers’ ability to require in-person attendance at the workplace? A decision from the U.S. 7th Circuit Court of Appeals (which covers Illinois, Indiana, and Wisconsin) offers solace to employers that believe certain jobs, especially supervisory ones, must be performed in person.

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Anna Kinney worked as a director of imaging services at St. Vincent Hospital in Evansville, Indiana. In that position, she was responsible for administering and monitoring the delivery of imaging services to patients. Though she didn’t directly provide medical services, she monitored the “plan for patient care services” and acted as a liaison between radiologists and others on the radiology staff and other department leaders. This included overseeing relevant equipment and supervising a team of about 120 people.

In 2018, Kinney applied for and was granted intermittent leave under the Family and Medical Leave Act (FMLA) based on diagnoses of anxiety disorder and post-traumatic stress disorder. She didn’t abuse her intermittent leave—she took only a couple of days from October 2018 through December 2020.