Background
Christine Klimek, a registered nurse with Complex Regional Pain Syndrome, was denied a medical exemption from a COVID-19 vaccine mandate by CentraCare Health System. After being placed on unpaid leave, she sued for failure to accommodate her disability under the Americans with Disabilities Act and the Minnesota Human Rights Act. The district court granted summary judgment for the employer, ruling that vaccination was an essential job function.
The court’s reasoning
The court held that vaccination is a means to an end, not an essential job function itself, and that an exemption is a form of accommodation, not a duty. The court found that CentraCare knew of Klimek’s disability and failed to request further information when needed, effectively cutting off the interactive process. Additionally, the court determined that CentraCare did not prove undue hardship in allowing Klimek to continue working remotely, as she had already been doing so without patient contact.
Adding the label of policy to a task does not render it an essential job function, and a duty does not become essential by the employer’s ipse dixit.
Opinion at page 6
What it means going forward
Employers must carefully distinguish between job duties and means to achieve safety goals when evaluating accommodation requests. The decision reinforces that employers bear the burden of requesting necessary information and cannot rely on hypothetical hardships to deny remote work accommodations.