Priscilla Conners v. Robert Wilkie, 984 F.3d 1255

Background:

Priscilla Conners, a licensed practical nurse (LPN) at a VA clinic, suffered severe injuries in October 2011 that left her with lasting physical limitations (limited standing/walking, need to elevate leg, lifting and bending restrictions).
After intermittent medical leaves and surgeries, her supervisor restricted her duties to teaching and paperwork because she could not perform core LPN tasks (patient care, immunizations, emergency response, front desk).
Conners completed formal accommodation/reassignment paperwork in 2013 requesting (inter alia) a private office, frequent leg elevation, a footstool, limits on standing and walking; the VA provided only a footstool and concluded she could not perform essential LPN functions even with accommodations.
The VA sought potential reassignments, but Conners listed only remote transfer locations and crossed out a standard certification on the reassignment form; VA contacts at other facilities reported no compatible LPN vacancies.
The VA offered reassignment to a different job, medical-disability retirement, or termination; Conners declined reassignment and retirement, did not contest a proposed removal within the 14-day period, and was terminated in January 2014.
Conners sued under the Rehabilitation Act alleging failure to accommodate, retaliation, and hostile work environment; the district court granted summary judgment to the VA on all claims, and Conners appealed only the accommodation claim.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Conners was a "qualified individual with a disability" able to perform the essential functions of an LPN with or without reasonable accommodation	Conners argued she could perform essential functions because she performed teaching and paperwork duties and could be accommodated to continue as an LPN	VA argued Conners’ limitations prevented performance of essential LPN duties (standing, walking, treating patients, immunizations, emergency response) even with accommodations	Held: Conners was not a qualified individual; undisputed evidence showed she could not perform essential LPN functions with or without reasonable accommodations
Whether the VA failed to reasonably accommodate Conners’ disability	Conners argued VA denied requested accommodations and did not meaningfully reassign her	VA contended it offered the footstool, explored reassignments, and reasonably concluded no LPN duties could be performed with accommodations; reassignment process was followed but no compatible vacancy existed	Held: Because Conners was not qualified for the LPN job, failure-to-accommodate claim fails; VA had no obligation to provide accommodations that would permit performance of essential duties
Whether VA failed to engage in the interactive process	Conners asserted VA did not adequately engage to identify reasonable accommodations	VA asserted it engaged (accommodation coordinator, reassignment inquiries) and that any alleged process failures are irrelevant if plaintiff cannot perform essential functions	Held: Even if process shortcomings existed, they are irrelevant because Conners failed to show she could perform essential functions with accommodations
Whether Conners established entitlement to reassignment to a vacant position	Conners argued reassignment should have been secured	VA argued Conners failed to show any available vacant position she could perform; her reassignment submissions were limited and noncompliant	Held: Conners did not present evidence she was qualified for any vacant VA position, so no discrimination via failure-to-reassign

Key Cases Cited

Lavallee v. Med-1 Sols., LLC, 932 F.3d 1049 (7th Cir. 2019) (standard for reviewing summary judgment and construing facts for nonmoving party)
Scheidler v. Indiana, 914 F.3d 535 (7th Cir. 2019) (elements of failure-to-accommodate claim)
Rodrigo v. Carle Found. Hosp., 879 F.3d 236 (7th Cir. 2018) (two-step inquiry on qualified individual and essential functions)
Gratzl v. Office of Chief Judges of 12th, 18th, 19th & 22nd Judicial Circuits, 601 F.3d 674 (7th Cir. 2010) (deference to employer’s judgment on essential functions)
Severson v. Heartland Woodcraft, Inc., 872 F.3d 476 (7th Cir. 2017) (plaintiff’s burden to show a vacant position for reassignment)
McCreary v. Libbey-Owens-Ford Co., 132 F.3d 1159 (7th Cir. 1997) (reassignment as a possible reasonable accommodation)
Sansone v. Brennan, 917 F.3d 975 (7th Cir. 2019) (interactive process principles and limits on relief for mere process failures)
Stern v. St. Anthony’s Health Ctr., 788 F.3d 276 (7th Cir. 2015) (interactive process is not an end in itself)
Brumfield v. City of Chicago, 735 F.3d 619 (7th Cir. 2013) (contrast of causation standards under Rehabilitation Act and ADA)