Nicole Owens v. State of Georgia, Governor's Office of Student Achievement, 52 F.4th 1327

Nicole Owens, a GOSA web content specialist, had a July 18, 2018 c-section and reported childbirth-related complications requiring two blood transfusions.
Owens returned to work remotely on August 6 with a physician note saying she “may” telework; she later informed GOSA on September 12 that she needed to telework until November 5 and provided a second doctor’s note saying only that she “may” continue telework until then.
GOSA (through HR and the Executive Director) asked Owens for additional medical documentation and sent reasonable-accommodation forms and a medical-release authorization; Owens did not return the completed release or required paperwork and did not tell GOSA her doctor’s records turnaround time.
GOSA set deadlines (final request: complete forms by Oct. 10 or return to office by Oct. 11); Owens missed the deadlines and was terminated on Oct. 11 for failing to provide documentation or return to the office.
Owens sued for failure to accommodate and retaliation under the Rehabilitation Act and for pregnancy discrimination under the PDA; the district court granted summary judgment to GOSA.
The Eleventh Circuit affirmed: an employee must identify a disability and explain how a requested accommodation would address its limitations to trigger an employer’s duty to accommodate; Owens’ communications were too vague, and she failed to show pretext on the other claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Owens’ telework request triggered GOSA’s duty under the Rehabilitation Act to provide a reasonable accommodation	Owens said childbirth-related complications required telework and provided doctor notes authorizing telework	GOSA said the notes were vague, did not identify a disability or explain how telework was medically necessary	Held: No. Employee must identify a disability and explain how requested accommodation addresses limitations; Owens failed to do so
Whether GOSA unlawfully retaliated against Owens for requesting accommodation	Owens argued she pursued protected activity and made efforts to obtain medical paperwork; termination was retaliatory	GOSA maintained it lawfully terminated Owens for failing to submit required accommodation forms or return to the office after warnings	Held: No pretext. Evidence shows legitimate, nondiscriminatory reasons for termination and no substantial evidence of discriminatory animus
Whether Owens’ termination violated the Pregnancy Discrimination Act	Owens argued termination was discrimination based on pregnancy/childbirth-related condition	GOSA argued termination was based on failure to comply with documentation/return-to-work requests, not pregnancy	Held: No. Same pretext analysis; plaintiff failed to show GOSA’s reasons were pretextual

Frazier-White v. Gee, 818 F.3d 1249 (11th Cir. 2016) (employee must make a specific accommodation demand and show it is reasonable)
D’Onofrio v. Costco Wholesale Corp., 964 F.3d 1014 (11th Cir. 2020) (interactive process and accommodation principles)
Lucas v. W.W. Grainger, Inc., 257 F.3d 1249 (11th Cir. 2001) (accommodation must enable performance of essential job functions)
Morisky v. Broward Cnty., 80 F.3d 445 (11th Cir. 1996) (employer must have knowledge of disability for liability)
Ward v. McDonald, 762 F.3d 24 (D.C. Cir. 2014) (employer needs information about nature of disability and requested accommodation)
Willis v. Conopco, Inc., 108 F.3d 282 (11th Cir. 1997) (requirements for triggering employer accommodation duties)
Sutton v. Lader, 185 F.3d 1203 (11th Cir. 1999) (Rehabilitation Act standards aligned with ADA)