Seventh Circuit Reiterates That Reasonable Accommodation Is Not Required for Employee Who Is Not a Qualified Individual With a Disability

Confirming two basic principles that apply under the Americans with Disabilities Act (ADA), the U.S. Court of Appeals for the Seventh Circuit has ruled that an employer is not required to reasonably accommodate an individual who is not qualified for his or her position. This includes not having to reallocate some of the job’s essential functions to non-disabled employees working in a “team” environment.

The ruling by the appeals court in EEOC v. AutoZone, Inc., No. 15-1753 (7th Cir. Jan. 4, 2016), upholds a lower court decision in which the jury concluded that an incumbent who was restricted from performing heavy lifting, an essential function of her job, was unqualified for the position and therefore not entitled to a reasonable accommodation, and that her employer had no obligation to reassign that essential function to other non-disabled employees.

A copy of the Seventh Circuit’s ruling in AutoZone is available here.