Joseph Mobley v. St. Luke's Health System, Inc., 53 F.4th 452

Joseph Mobley, Patient Access Supervisor at St. Luke’s since 2016, supervised ~20 employees; most of his direct reports regularly teleworked.
Mobley was diagnosed with multiple sclerosis (MS) in 2016 and experienced episodic flare-ups that impaired walking, standing, breathing, and caused fatigue and sensory symptoms.
St. Luke’s had a telework policy (one day/week, later two days/week) and managers could permit additional telework case-by-case; Mobley regularly teleworked under that arrangement.
Mobley requested a blanket accommodation to telework during MS flare-ups (Dec 2017 and Feb–Mar 2018); St. Luke’s denied a blanket accommodation, offering case-by-case telework and suggesting use of PTO/FMLA when needed; only one request was expressly denied and he used PTO that day.
Mobley resigned in Aug 2018 (stated fear of potential discharge but did not notify employer); he sued under the ADA, MHRA, Title VII, and § 1981, but appealed only MHRA disability-discrimination and ADA/MHRA failure-to-accommodate claims after the district court granted summary judgment for St. Luke’s.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to accommodate (qualified individual / essential functions)	Mobley: he could perform essential duties and supervise remotely; telework during flare-ups is a reasonable accommodation.	St. Luke’s: job required in-person supervision; flare-ups unpredictable; remote work during flare-ups would impair essential functions.	Court: disputed material fact exists whether Mobley could perform essential functions with the proposed accommodation, so prima facie could be met.
Interactive-process obligation	Mobley: employer failed to engage in the interactive process in good faith over his telework request.	St. Luke’s: allowed case-by-case telework, offered PTO/FMLA, invited follow-up; only one denial recorded.	Court: St. Luke’s engaged in the interactive process in good faith; no triable issue on this element; summary judgment affirmed.
MHRA disability-discrimination claim	Mobley: alleged disability-based discrimination under MHRA.	St. Luke’s: moved for summary judgment as to all claims.	Court: affirmed district court’s judgment (claims fail consistent with accommodation/interactive-process analysis).
Constructive discharge	Mobley: resigned because he feared termination due to disability.	St. Luke’s: procedural defenses—claim not exhausted before EEOC and not argued below.	Court: constructive-discharge claim not properly before the court (no EEOC exhaustion; not argued below); dismissal affirmed.

Whittington v. Tyson Foods, Inc., 21 F.4th 997 (8th Cir. 2021) (standard of review for summary judgment)
Ehlers v. Univ. of Minnesota, 34 F.4th 655 (8th Cir. 2022) (ADA discrimination and reasonable-accommodation principles)
Mole v. Buckhorn Rubber Prod., Inc., 165 F.3d 1212 (8th Cir. 1999) (ADA and state-law framework alignment)
Huber v. Wal-Mart Stores, Inc., 486 F.3d 480 (8th Cir. 2007) (elements of failure-to-accommodate prima facie case)
Hill v. Walker, 737 F.3d 1209 (8th Cir. 2013) (qualified individual analysis)
Fenney v. Dakota, Minnesota & E. R. Co., 327 F.3d 707 (8th Cir. 2003) (skills and ability to perform essential functions analysis)
U.S. Airways, Inc. v. Barnett, 535 U.S. 391 (2002) (reasonable-on-its-face accommodation requirement)
Fjellestad v. Pizza Hut of Am., Inc., 188 F.3d 944 (8th Cir. 1999) (interactive-process duty and good-faith effort standard)
Sharbono v. N. States Power Co., 902 F.3d 891 (8th Cir. 2018) (elements to show employer failed to engage in interactive process)
Garrison v. Dolgencorp, LLC, 939 F.3d 937 (8th Cir. 2019) (interactive process steps can satisfy employer’s obligations)
Brunckhorst v. City of Oak Park Heights, 914 F.3d 1177 (8th Cir. 2019) (remote-work accommodation analysis)
Evans v. Coop. Response Ctr., Inc., 996 F.3d 539 (8th Cir. 2021) (distinction between leave requests and telework accommodations)
Peyton v. Fred’s Stores of Ark., Inc., 561 F.3d 900 (8th Cir. 2009) (interactive-process precedent)