Visually impaired employee's request held unreasonable

The U.S. 10th Circuit Court of Appeals (whose rulings apply to all Kansas and Oklahoma employers) recently held a hospital employee's visual impairment, which complicated her daily commute to and from work, didn't entitle her to her requested accommodation of a flexible work schedule. The case emphasizes that employers have no obligation under the Americans with Disabilities Act (ADA) to accommodate employees' non-work-related barriers created by personal lifestyle choices.

Facts

Joan Unrein worked as a clinical dietitian at the Colorado Plains Medical Center (also known as PHC-Fort Morgan, Inc.) for almost two decades. Though she lived in the rural town of Fleming, Colorado, approximately 60 miles from the hospital, the extensive 120-mile round-trip commute presented no problem for her or her employer ― until it did.

When Unrein became legally blind, she could no longer drive herself to and from work. Consequently, she had to rely on rides from friends and family, but they were often unavailable for such a significant commute. The transportation barrier created a problem because she could no longer guarantee when she would be physically present at the hospital. As a result, she requested a flexible work schedule to accommodate her transportation.