Specific Accommodation Requests and Evidence of “Taint” in Federal‑Sector Employment

Commentary on Teresa Boyd v. U.S. Postmaster General (11th Cir. Dec. 3, 2025)

I. Introduction

The Eleventh Circuit’s unpublished per curiam decision in Teresa Boyd v. U.S. Postmaster General, No. 23‑12536 (11th Cir. Dec. 3, 2025), offers a compact but important synthesis of several strands of federal‑sector employment law:

the “taint” standard for federal employees’ race, sex, and age discrimination claims under Title VII and the ADEA,
the requirement that a disabled federal employee make a specific request for a reasonable accommodation under the Rehabilitation Act, and
the proof needed to connect alleged retaliation to EEO activity under Title VII’s federal‑sector provision.

Although “NOT FOR PUBLICATION” and therefore non‑precedential, the opinion is a useful roadmap for practitioners litigating discrimination, disability accommodation, and retaliation claims in the federal sector, especially within the Eleventh Circuit. It is particularly notable for its clear insistence that:

workers’ compensation medical documentation (such as CA‑17 forms) does not by itself amount to a request for reasonable accommodation, and
even under the more plaintiff‑friendly Babb/Buckley “taint” standard, a federal employee must produce actual evidence that a protected characteristic or protected activity played some role in a personnel action.

II. Factual and Procedural Background

A. The Parties and Employment Setting

Teresa Boyd is a Black woman over 60 who has worked for the United States Postal Service (USPS) since 1998. At the relevant times, she was a full‑time carrier technician at the Lake Jackson station in Tallahassee, Florida. Her core duties were:

organizing mail and packages for assigned routes, and
driving a postal truck to deliver them.

Boyd was also heavily involved in union activity: she became a shop steward in 2008 and the union president in 2018.

B. Workplace Accidents and Medical Restrictions

Boyd suffered two on‑duty motor vehicle accidents involving her USPS truck:

February 2015: Neck and back strains.
October 2016: Finger, wrist, and ulnar nerve injuries.

She filed workers’ compensation claims for both incidents. After the second accident, USPS stated there was no work within her medical restrictions and kept her out of work until October 2017, when she returned full‑time with a 25‑pound lifting restriction.

In May 2019 she had a flare‑up of her ulnar nerve (hand/arm) injury, and her doctor temporarily restricted her from driving. By August 2019, her doctors generally cleared her to drive, but with two important limitations:

She had a lifting restriction (initially 15 pounds, later 25 pounds).
She experienced neck “flare‑ups” several times a year, during which she could not turn her head and thus could not safely drive a postal vehicle for a few days at a time.

These restrictions were repeatedly documented in “Duty Status Reports” (CA‑17 forms) and accompanying letters in August 2019 and again in November 2019, January 2020, and February 2020. The February 2020 CA‑17, for example, stated:

Boyd could drive 4–6 hours per day generally and work full days,
but during flare‑ups (about four times a year, lasting a few days) she could not turn her head and therefore could not drive a postal vehicle.

C. Limited Duty Work and Conflicts with Management

From May to October 2019, Boyd performed full‑time limited duty. On August 29, 2019, however, after she submitted a union “request for information” to her supervisor, Waylon Morrison, she was placed on a one‑day “emergency placement” (unpaid removal from duty). Boyd claimed the union contract allowed such placement only for:

causing injury,
being intoxicated on duty, or
for the safety of the post office.

On October 22, 2019, a similar conflict escalated: Boyd submitted several requests for information as union representative; Morrison ordered her to leave and placed her on unpaid emergency placement. She briefly reentered the building to retrieve her forgotten keys, and station manager Matthew Staley allegedly threatened to call the police if she did not leave.

On October 25, 2019, Boyd initiated an informal EEO complaint alleging discrimination based on race, sex, age, and disability relating to the October 22 incident and emergency placement. Morrison was interviewed about the incident approximately a month later.

On October 26, 2019, Boyd returned to work for what she believed would be a fact‑finding meeting about the October 22 events. Instead, Morrison told her there were no assignments within her medical restrictions and refused to let her resume her full‑time position. Boyd says she asked to return to her job; Morrison responded that no work existed within her restrictions.

On November 14, 2019, Boyd received a two‑week suspension for the October 22 incident, based on allegations she yelled and acted aggressively toward Morrison. She filed grievances against both the emergency placement and the suspension, and both grievances were upheld, with the discipline expunged from her record.

Eventually, on February 11, 2020, Morrison offered Boyd a very limited duty assignment—casing mail for one of her routes—for only 1.5 hours per day. Boyd objected that she was capable of doing her full job. Morrison maintained this was the only work available within her restrictions. On union advice, Boyd accepted the 1.5‑hour assignment to preserve her employment.

D. Parking Dispute, Further Discipline, and Restrictions

On May 15, 2020, supervisor Paul Steele challenged Boyd for parking in the customer lot, which she said she had done for 15 years without issue. Several days later, on May 21, 2020, acting station manager Vanessa Cobb (previously the subject of an EEO charge by Boyd) yelled at Boyd to park in the employee lot and then placed her on emergency placement the next day. Boyd amended her October 2019 EEO complaint to add these events.

In July 2020, Boyd received a notice of removal related to the May 21 incident. She grieved this action as well, and it was expunged from her file. When she resumed the 1.5‑hour limited duty assignment in September 2020:

she was required to leave immediately when her short shift ended, and
she was barred from entering any other postal station in Tallahassee.

E. Reasonable Accommodation Committee Contacts

In February and March 2021, Boyd received three letters from the USPS District Reasonable Accommodation Committee, asking her to submit medical documentation and forms regarding a possible accommodation. This Committee is the agency’s established mechanism for handling reasonable accommodation requests.

Boyd had known about the Committee for years but had never approached it herself. In this instance, the Committee initiated contact with her. She ultimately declined to participate in the Committee’s process.

F. Litigation in the District Court

In June 2021, Boyd sued the Postmaster General in federal court (Northern District of Florida), asserting:

Race, sex, and age discrimination under:
- Title VII, 42 U.S.C. § 2000e‑16(a) (federal sector), and
- the ADEA’s federal‑sector provision, 29 U.S.C. § 633a(a);
Disability discrimination under the Rehabilitation Act, 29 U.S.C. § 794; and
Retaliation under Title VII’s federal‑sector provisions.

Following discovery, USPS moved for summary judgment on all claims. After hearing, the district court:

granted summary judgment on the race, sex, age, and disability discrimination claims, and
initially allowed the retaliation claim to proceed, subject to Boyd clarifying which alleged adverse actions she was challenging.

After Boyd filed a clarifying notice and USPS renewed its motion, the court granted summary judgment on the retaliation claim as well, finding no evidence of a causal connection between Boyd’s protected activity and the alleged acts of retaliation.

Boyd appealed to the Eleventh Circuit.

III. Summary of the Eleventh Circuit’s Opinion

The Eleventh Circuit, reviewing summary judgment de novo, affirmed across the board. During oral argument, Boyd narrowed her theory significantly: she identified a single core “personnel action” as the basis for all three discrimination claims (race, sex, age, and disability)—namely the Postal Service’s long‑term refusal, from 2016 onward, to grant her a limited‑duty assignment beyond the 1.5 hours per day eventually offered in 2020.

The panel’s holdings can be summarized as follows:

Race, Sex, and Age Discrimination: Boyd failed to produce any admissible evidence that her protected characteristics played any role in the decision not to give her more extensive limited duty work. Bare assertions that younger, white, or male employees were treated better were deemed “unsubstantiated assertions” insufficient to defeat summary judgment.
Disability (Rehabilitation Act):
- USPS conceded Boyd had a disability.
- The court accepted that driving a postal vehicle is an essential function of a carrier technician’s job.
- Boyd’s flare‑ups prevented her from driving on certain days, and she argued that using leave or temporary reassignment during those short periods would allow her to be “qualified” for her position.
- The court held that Boyd failed to make a specific request for reasonable accommodation and, in any event, failed to carry her burden of proposing and substantiating a reasonable accommodation that would enable her to perform the essential functions of the job.
Retaliation: Although Boyd engaged in protected activity by contacting the EEO, she failed to show:
- that the key decisionmakers knew of her protected activity at the time they took the challenged actions, or
- that the timing and circumstances otherwise supported an inference that retaliation “played any part” in the decision‑making process.
Several challenged actions occurred before any protected activity; others occurred months later, with gaps of about three months—too long, without more, to support an inference of causation. Summary judgment was affirmed.

IV. Detailed Analysis

A. Overall Legal Framework

The opinion sits at the intersection of three doctrinal frameworks:

Federal‑sector discrimination under Title VII and the ADEA. Following the Supreme Court’s decision in Babb v. Wilkie (“Babb I”) and the Eleventh Circuit’s own Babb II and Buckley, federal‑sector personnel actions must be “free from any discrimination,” meaning a plaintiff need only show that a protected characteristic tainted the decision‑making process in any way—though stricter standards govern certain remedies.
Disability discrimination under the Rehabilitation Act. The Rehabilitation Act incorporates the substantive standards of the Americans with Disabilities Act (ADA). The plaintiff must show she is a “qualified individual with a disability,” i.e., able to perform the essential functions of the job with or without a reasonable accommodation—and she bears the burden of identifying and demonstrating a reasonable accommodation.
Retaliation under the federal‑sector provision of Title VII. Retaliation is treated as a form of “discrimination” for federal‑sector purposes. A plaintiff must still prove, at a minimum, that:
- she engaged in protected activity,
- she suffered an adverse personnel action, and
- her protected activity tainted the decision‑making process (which in turn requires proof that the decisionmaker knew of the protected activity and that the timing and other evidence support an inference of retaliatory motive).

The court works through each of Boyd’s claims under these frameworks, consistently emphasizing two themes:

the evidentiary burden at summary judgment (claims cannot rest on speculative or conclusory assertions), and
the need for specificity, particularly in the disability context (a generalized desire to “come back to work” is not a request for a legally cognizable accommodation).

B. Race, Sex, and Age Discrimination Claims

1. The Applicable Standard: “Taint” in Federal‑Sector Personnel Actions

For federal employees, Title VII and the ADEA require that “all personnel actions” be made “free from any” discrimination. Drawing on Babb I, Babb II, and Buckley v. Secretary of Army, the panel reiterates the key rule:

“[A] federal employer violates the law if it allows race [or other prohibited] discrimination to contribute to any personnel action—even if the federal employer would have made precisely the same decision had it not engaged in race discrimination.”

Thus, unlike private‑sector Title VII and ADEA cases, federal employees need not prove that discrimination was the but‑for cause of an adverse action to establish a statutory violation. Any discriminatory contribution or taint in the decision‑making process suffices to violate the federal‑sector provisions.

But this relaxed causation standard does not eliminate the threshold requirement that a plaintiff produce some actual evidence that discrimination played a part in the decision.

2. Boyd’s Evidence and the Court’s Evaluation

Boyd’s discrimination theory was that USPS refused to provide her a full‑time limited duty assignment—beyond the 1.5 hours per day offered—because of her race (Black), sex (female), and age (over 60). She broadly asserted that:

younger, white, and male employees received full‑time limited duty assignments, and
these groups were generally treated better than she was.

The court held that these assertions were conclusory and unsupported by the record. It emphasized:

Boyd did not identify any specific co‑workers as comparators.
She offered no details about their injuries, restrictions, job duties, or how they were allegedly treated better.
She did not provide documents, testimony, or any other evidence from which the court could determine whether supposed comparators were “similarly situated in all material respects” under Lewis v. City of Union City (Lewis I) and Lewis II.

The panel explicitly notes that Boyd is not required to use the rigid McDonnell Douglas burden‑shifting framework or to establish a comparator‑based prima facie case. Under modern Eleventh Circuit precedent (Lewis II), circumstantial discrimination evidence can consist of:

“suspicious timing,”
ambiguous statements or other facts showing discriminatory animus,
systematically better treatment of similarly situated employees, or
evidence of pretext.

But she must still produce some admissible evidence. Here, she did not. Her allegations about the better treatment of unnamed white, male, or younger employees were “unsubstantiated assertions,” which, under Anthony v. Georgia and Stewart v. Happy Herman’s, cannot defeat a well‑supported summary judgment motion.

Under the Babb/Buckley “taint” standard, a federal employer’s personnel actions must be entirely free from discriminatory influence. Yet the employer’s decision cannot be found “tainted” unless the plaintiff points to evidence that discrimination actually played some role in the decision. The panel concludes that Boyd failed to do so:

“In sum, Boyd presented only unsubstantiated assertions of race, sex, or age discrimination, which are insufficient to raise a genuine issue of material fact necessary to avoid summary judgment.”

C. Disability Discrimination Under the Rehabilitation Act

1. The Governing Standards

The Rehabilitation Act prohibits federal agencies from discriminating in employment against “otherwise qualified” individuals with disabilities. Through 29 U.S.C. § 794(d), it incorporates the substantive standards of the ADA.

To establish a prima facie Rehabilitation Act claim, a plaintiff must show:

She has a disability.
She is an “otherwise qualified” individual—she can perform the essential functions of her position with or without a reasonable accommodation.
She was subjected to unlawful discrimination because of her disability.

“Essential functions” are “fundamental job duties,” not marginal or incidental tasks. The employee bears the burden of:

identifying a specific accommodation, and
demonstrating that the accommodation is reasonable—i.e., that it would enable her to perform the essential functions of the job. (See Lucas v. W.W. Grainger, Inc. and Frazier‑White v. Gee.)

2. Disability and Essential Functions

USPS did not dispute that Boyd had a disability as a result of her workplace injuries. The opinion identifies two main medical limitations relevant to her position as a carrier technician:

a lifting restriction (ultimately 25 pounds), and
intermittent neck “flare‑ups” about four times per year, lasting a few days each, during which she could not turn her head and therefore could not drive.

Everyone agreed that driving a postal truck is an essential function of a carrier technician’s job. During flare‑ups—8 to 12 days per year—Boyd testified she could not safely drive. She also indicated she was aware of the onset of flare‑ups before starting work for the day.

The lifting restriction was already being accommodated and was not the focus of the dispute. The central question was whether Boyd was “qualified” given her intermittent inability to drive, and whether there was a reasonable accommodation that would allow her to maintain her position.

3. Boyd’s Proposed Accommodations

On appeal, Boyd argued that USPS could have reasonably accommodated her by:

allowing her to use leave during flare‑ups, or
temporarily reassigning her to other duties during flare‑ups (e.g., limited duty work not involving driving).

The district court (and, affirming, the Eleventh Circuit) rejected reassignment as unreasonable in the circumstances, noting precedent that:

employers are not required to reallocate essential job duties or to change what constitutes an essential function (Earl v. Mervyns, Inc.), and
they are not obligated to create a permanent light‑duty position as an accommodation (Frazier‑White).

The panel accepted that principle, but ultimately decided the claim on a more fundamental ground: Boyd never made a specific request for reasonable accommodation, and she did not carry her burden of demonstrating that leave or reassignment was, in fact, a reasonable accommodation.

4. The “Specific Demand” Requirement

A core holding of the opinion is that the duty to provide a reasonable accommodation is not self‑executing. It arises only when the employee:

makes a specific demand for an accommodation, and
identifies how that accommodation would enable her to perform essential job functions. (See Gaston v. Bellingrath Gardens & Home, Inc. and Owens v. Governor’s Office of Student Achievement.)

The court emphasizes that Boyd:

did advise USPS of her medical restrictions via CA‑17 forms and doctor’s letters, and
told supervisors she wanted to “come back to work.”

But this was not enough. The forms simply documented her limitations; they did not propose a specific accommodation (such as taking leave during flare‑ups or working alternative duties). Her in‑person request to “come back to work” was likewise insufficiently specific:

“Although Boyd identified her disability and explained why it rendered her unable to do her job without accommodation, she did not make a ‘specific demand’ for any accommodation.”

In other words:

CA‑17 forms and medical notes == medical information.
A proper accommodation request == a concrete proposal: “I need to use leave on days when my neck flare‑ups prevent me from driving” or “Please assign me to casing work only during those days.”

The panel treats the USPS Reasonable Accommodation Committee’s letters (sent in 2021) as confirmation that USPS has an established process for handling such requests. It underscores that Boyd, who knew about the Committee, never initiated a request through that channel and declined to participate when the Committee reached out to her. This, too, cut against her claim.

5. The Reasonableness of Leave as an Accommodation

Boyd further argued that allowing her to use leave on flare‑up days would have been a reasonable accommodation. The court did not reject the concept outright—leave can sometimes be a reasonable accommodation—but found that Boyd offered no evidentiary support for her argument:

She claimed she used her own leave from November 2017 to May 2019 to work full‑time, but she cited no record evidence (deposition, documents, or declaration) to substantiate this.
Her deposition suggested that her neck problems did not require her to avoid driving during that period, and that the May 2019 cessation of driving was due to her hand injury, not her neck.
The record lacked evidence on how much leave she had available or how often she actually used leave for flare‑ups.

This leaves the court unable to determine whether the requested leave would:

simply amount to “periodic absences” consistent with being qualified, or
instead require someone else to regularly perform the essential driving function in her place—making her not “qualified” for the carrier job at all under Cramer v. State of Florida.

Because Boyd failed to:

make a clear, specific request for leave as an accommodation, and
present evidence showing that such leave would have enabled her to perform the essential functions of her job,

she did not meet her burden of showing a reasonable accommodation existed. The panel therefore affirmed summary judgment on the Rehabilitation Act claim:

“Because Boyd fails to meet her ‘burden of persuasion’ that a reasonable accommodation exists, much less that she requested one in the first place, we affirm the district court’s judgment on Boyd’s claim for disability discrimination.”

D. Retaliation Under Title VII’s Federal‑Sector Provision

1. Legal Standard

Title VII’s federal‑sector provision, 42 U.S.C. § 2000e‑16(a), prohibits “discrimination” against federal employees. The Eleventh Circuit has held that retaliation for EEO activity falls within this concept of “discrimination.” As a result, Babb II and Buckley apply: federal personnel actions must be “free from any retaliatory taint.”

A plaintiff may prove retaliation under the familiar McDonnell Douglas framework by showing:

protected activity (e.g., filing an EEO complaint),
an adverse personnel action, and
a causal link between the two.

“Causation” in this context means evidence from which a reasonable jury could find that retaliation “played any part” in the employer’s decision. Crucially, this requires proof that:

the relevant decisionmaker knew of the protected activity at the time of the decision, and
the timing and other circumstantial evidence support an inference of retaliatory motive. (See Patterson v. Georgia‑Pacific.)

Temporal proximity can support an inference of causation, but as Thomas v. Cooper Lighting and Buckley make clear, “mere temporal proximity” must be “very close.” Three to four months, without more, has consistently been held too long to support an inference of causation as a matter of law.

2. Application to Boyd’s Claim

Boyd alleged a series of retaliatory acts, including:

emergency placements,
suspensions and a notice of removal,
restriction to a 1.5‑hour limited duty assignment, and
being banned from entering other postal stations and ordered to leave her own station immediately after her short shift ended.

The Eleventh Circuit, like the district court, concluded that Boyd’s claim failed for lack of evidence on causation:

Pre‑EEO events: The October 22, 2019 emergency placement and Staley’s threat to call the police occurred before Boyd’s initial EEO contact on October 25. Events that predate protected activity, by definition, cannot be retaliatory responses to it.
October 26 meeting & November 14 suspension: Although these events occurred shortly after the October 25 EEO contact, the record showed that Morrison—the key decisionmaker—did not know about her EEO contact at the time. His EEO interview occurred a month later (November 25). Without knowledge, there can be no causal connection.
February 11, 2020 job offer (1.5 hours limited duty): This occurred more than three months after the initial EEO contact and before her February 14, 2020 EEO contact. The gap is too long, absent other evidence, to infer causation.
May 2020 incidents and May 22 emergency placement: These occurred about three months after Boyd’s February 14 EEO contact. Again, under Thomas, three months is too long, without more, to support an inference of causation.
July 2020 notice of removal: Although Boyd had amended her EEO complaint to add the May events by then, there was no evidence that the decisionmakers responsible for the removal notice knew about that protected activity.
Restrictions on entering stations and having to leave after shift: Likewise, there was no evidence that whoever imposed these restrictions knew of Boyd’s EEO activity at the relevant times.

In short, Boyd did not provide:

direct evidence of retaliatory motive,
evidence of knowledge of her protected activity by the decisionmakers at the time of the acts, or
other circumstantial evidence that might bridge the gap created by the three‑month or greater time intervals.

The panel therefore held that there was no triable issue on whether retaliation “played any part” in the personnel actions at issue.

V. Precedents Cited and Their Influence

The opinion leans heavily on recent and longstanding Eleventh Circuit and Supreme Court precedents. Key cases include:

A. Summary Judgment and Evidentiary Standards

Anthony v. Georgia, 69 F.4th 796 (11th Cir. 2023): Reaffirms that summary judgment is appropriate when, viewing the evidence in the light most favorable to the non‑movant, there is no genuine dispute of material fact. “Unsubstantiated assertions” are not sufficient.
Stewart v. Happy Herman’s Cheshire Bridge, Inc., 117 F.3d 1278 (11th Cir. 1997): A “genuine dispute” exists only if a reasonable jury could return a verdict for the non‑movant.

These cases undergird the court’s rejection of Boyd’s unsupported assertions about comparator treatment.

B. Federal‑Sector Discrimination Under Title VII and the ADEA

Babb v. Wilkie (“Babb I”), 589 U.S. 399 (2020): The Supreme Court held that the ADEA’s federal‑sector provision requires personnel actions to be “untainted by any consideration of age.” Age need not be a but‑for cause for a statutory violation, though but‑for causation may still be required for certain remedies.
Babb v. Secretary, Department of Veterans Affairs (“Babb II”), 992 F.3d 1193 (11th Cir. 2021): The Eleventh Circuit implemented Babb I, articulating the “taint” standard and explaining how remedies are affected.
Buckley v. Secretary of Army, 97 F.4th 784 (11th Cir. 2024): Reaffirmed that under the federal‑sector provisions, a plaintiff shows a violation if discrimination contributes to the process of decision‑making in any way, even if the same decision would have been made absent discrimination. Also clarified that retaliation is a form of “discrimination” covered by § 2000e‑16(a).
Terrell v. Secretary, Department of Veterans Affairs, 98 F.4th 1343 (11th Cir. 2024): Applied and reinforced the Babb/Buckley framework, emphasizing the breadth of the “taint” standard.

In Boyd, these cases supply the doctrinal backdrop: USPS could not lawfully allow race, sex, age, or retaliation to influence its personnel decisions. But without evidence of such influence, Boyd’s claims failed.

C. Comparators and Circumstantial Evidence of Discrimination

Lewis v. City of Union City (Lewis I), 918 F.3d 1213 (11th Cir. 2019) (en banc): Clarified that a comparator must be “similarly situated in all material respects” to be useful in a McDonnell Douglas analysis.
Lewis v. City of Union City (Lewis II), 934 F.3d 1169 (11th Cir. 2019): Discussed the broader range of circumstantial evidence that can be used to show discriminatory intent, beyond or in addition to comparators.
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973): The classic burden‑shifting framework for circumstantial evidence discrimination cases.

The court relies on Lewis II to emphasize that a plaintiff can use multiple forms of circumstantial evidence, but Boyd offered none of the necessary specifics or corroboration.

D. Rehabilitation Act / ADA Standards

Mullins v. Crowell, 228 F.3d 1305 (11th Cir. 2000): The Rehabilitation Act prohibits federal employers from discriminating against qualified individuals with disabilities.
Owens v. Governor’s Office of Student Achievement, 52 F.4th 1327 (11th Cir. 2022): Because the Rehabilitation Act adopts ADA standards, ADA case law is precedent for Rehabilitation Act cases. Reiterates that an employee must identify her disability and suggest how the requested accommodation will overcome it.
Garrett v. University of Alabama at Birmingham Board of Trustees, 507 F.3d 1306 (11th Cir. 2007): Sets out the elements of a prima facie case of disability discrimination.
Lucas v. W.W. Grainger, Inc., 257 F.3d 1249 (11th Cir. 2001): Clarifies that to be “qualified,” the employee must be able to perform essential functions with or without a reasonable accommodation and that the employee bears the burden of identifying a reasonable accommodation.
Holly v. Clairson Industries, L.L.C., 492 F.3d 1247 (11th Cir. 2007): Defines “essential functions” as fundamental job duties.
Samson v. Federal Express Corp., 746 F.3d 1196 (11th Cir. 2014): Reiterates that essential functions do not include marginal job tasks.
Frazier‑White v. Gee, 818 F.3d 1249 (11th Cir. 2016): Holds that employers are not required to create a permanent light‑duty position as a reasonable accommodation.
Earl v. Mervyns, Inc., 207 F.3d 1361 (11th Cir. 2000): Employers are not obligated to reallocate essential functions or alter the fundamental nature of a job as an accommodation; the plaintiff bears the burden of proving a reasonable accommodation exists.
Gaston v. Bellingrath Gardens & Home, Inc., 167 F.3d 1361 (11th Cir. 1999): An employer’s duty to accommodate is not triggered until the employee makes a specific demand for an accommodation.
Cramer v. State of Florida, 117 F.3d 1258 (11th Cir. 1997): An employee is not “qualified” if she must regularly have someone else perform essential functions in her place.

These authorities collectively support the panel’s conclusion that:

Boyd had to make a suitably specific accommodation request,
she had to show that accommodation would allow her to perform essential functions, and
she failed on both points.

E. Retaliation and Causation

Rosado v. Secretary, Department of the Navy, 127 F.4th 858 (11th Cir. 2025): Confirms that the McDonnell Douglas framework may be used to establish a prima facie case of Title VII retaliation in the federal sector.
Patterson v. Georgia‑Pacific, LLC, 38 F.4th 1336 (11th Cir. 2022): Establishes that a plaintiff must show the “relevant decisionmaker was aware of the protected conduct” to establish causation in retaliation claims.
Thomas v. Cooper Lighting, Inc., 506 F.3d 1361 (11th Cir. 2007): Holds that, absent other evidence, a three‑to‑four‑month gap between protected activity and adverse action is too long to establish causation by temporal proximity alone.

These cases are central to the panel’s conclusion that Boyd did not show any actionable causal link between her EEO activity and the alleged retaliatory acts.

VI. Practical Impact and Implications

A. For Federal Employees and Their Counsel

The opinion underscores several practical lessons:

Evidence matters, even under the “taint” standard. The relaxed causation standard in federal‑sector discrimination and retaliation cases does not relax the evidentiary burden at summary judgment. Plaintiffs still must:
- identify specific facts, witnesses, and documents,
- present concrete comparator evidence where relevant, and
- tie specific decisions to specific discriminatory or retaliatory motives.
Clarity in pleadings and argument is crucial. Both the district court and the Eleventh Circuit remarked on the difficulty of deciphering which facts corresponded to which legal claims in Boyd’s presentation. On appeal, she narrowed her theory during oral argument. This illustrates the importance of:
- clearly identifying each “personnel action” at issue, and
- explaining which statute (Title VII, ADEA, Rehabilitation Act, retaliation) each action implicates.

B. For Reasonable Accommodation Practice

The most salient practical takeaway for disability law is the reiteration—and application—of the “specific demand” rule:

Informing the employer of one’s medical limitations is not the same as requesting a reasonable accommodation.
Workers’ compensation documents like CA‑17 forms, without more, do not constitute an accommodation request.
Vague pleas to “come back to work” or “be allowed to work” are not sufficiently specific.

Employees and advocates should:

submit explicit written accommodation requests,
describe the disability, the work limitations, and the specific accommodation sought (e.g., “use sick leave during flare‑ups,” “temporary non‑driving duties during flare‑ups”), and
take advantage of formal reasonable accommodation processes, such as USPS’s District Reasonable Accommodation Committee.

For employers, the case reinforces the importance of:

maintaining and publicizing a formal accommodation process,
distinguishing between workers’ compensation “limited duty” programs and ADA/Rehabilitation Act accommodation obligations, and
documenting communications about accommodations (or the lack of requests).

C. For Unions and Contractual Remedies

Boyd successfully grieved multiple disciplinary actions, resulting in expungements. However, the Eleventh Circuit’s analysis makes clear that:

Winning a grievance under a collective bargaining agreement does not automatically establish a statutory violation under Title VII, the ADEA, or the Rehabilitation Act.
Contractual violations may coexist with lawful, non‑discriminatory motives—or may be remedied solely under labor law without implying illegal discrimination or retaliation.

Union representatives should ensure that when they suspect discrimination or retaliation, they:

pursue both grievance and EEO routes, and
develop a separate evidentiary record tailored to statutory standards (e.g., comparators, discriminatory statements, temporal proximity linked to knowledge).

D. For Litigation Strategy

The opinion also illustrates strategic points for litigants:

Retaliation claims require proof of decisionmaker knowledge. Plaintiffs must identify who made each challenged decision and show that those individuals knew of the protected activity at the time.
Temporal proximity has limits. Gaps of about three months or more, standing alone, will rarely suffice to show causation. Other evidence (e.g., direct statements, patterns, or irregularities) is needed.
Scattershot theories are disfavored. Courts look more favorably on well‑defined, coherent claims that clearly connect legal theories to specific facts.

VII. Simplifying Key Legal Concepts

For non‑lawyers, several of the legal concepts in the opinion can be briefly explained as follows:

Summary Judgment: A procedural device where the judge decides a case without a trial because, even taking the non‑moving party’s evidence as true, there is no “genuine” factual dispute requiring a jury’s decision and the moving party is entitled to judgment as a matter of law.
Prima Facie Case: The initial set of facts that, if assumed true, are enough to support a legal claim and shift the burden of production to the other side (e.g., showing you are in a protected class, suffered an adverse action, and were treated worse than similarly situated colleagues).
Essential Functions: The core duties of a job—things that are fundamental to the position, not incidental or minor tasks. For a USPS carrier technician, driving a mail truck is an essential function.
Reasonable Accommodation: A change to the workplace or job duties that allows a disabled employee to perform essential job functions, so long as it does not impose an undue hardship on the employer or fundamentally change the job (for example, providing specialized equipment, modified schedules, or short‑term leave).
Light Duty vs. Reasonable Accommodation: “Light duty” is often a temporary assignment for injured workers, especially in workers’ compensation settings. A “reasonable accommodation” is a legal concept under the ADA/Rehabilitation Act. Employers are not required to create permanent light‑duty roles as accommodations.
Federal‑Sector “Taint” Standard: In the federal government, personnel actions must be “free from any” discrimination or retaliation. If discrimination or retaliation influences the decision‑making process in any way, the law is violated—even if the outcome would have been the same. But the plaintiff must still prove some evidence of discriminatory or retaliatory influence.
Temporal Proximity: How close in time an adverse action is to an employee’s protected activity (like filing an EEO complaint). Very close timing (e.g., days or weeks) can suggest retaliation; several months are usually not enough by themselves.
Personnel Action: Any significant employment decision, such as hiring, firing, promotion, suspension, assignment of duties, or placement on unpaid status.

VIII. Conclusion

The Eleventh Circuit’s decision in Boyd v. U.S. Postmaster General, though unpublished, offers clear guidance on three important fronts in federal‑sector employment law:

It reaffirms that under the Babb/Buckley “taint” standard, federal employees must still present actual evidence of discriminatory or retaliatory influence—speculation and unsupported assertions will not survive summary judgment.
It underscores that a disabled employee must make a specific, concrete request for a reasonable accommodation and carry the burden of showing how that accommodation would enable her to perform the essential functions of the job. Workers’ compensation medical forms, by themselves, are not enough.
It illustrates the strict requirements of retaliation claims: the plaintiff must show the decisionmaker’s knowledge of the protected activity and sufficiently close timing (or other evidence) to support an inference that retaliation played a part in the action.

In the broader legal context, the opinion harmonizes several recent Eleventh Circuit precedents on federal‑sector discrimination and reasonable accommodation, while offering practical lessons for federal employees, agencies, and counsel on how to frame, document, and litigate such claims. Even as a non‑precedential decision, it is a useful template for understanding how courts will apply the “taint” standard and the “specific demand” rule in day‑to‑day federal employment disputes.

Specific Accommodation Requests and Evidence of “Taint” in Federal‑Sector Employment: Commentary on Teresa Boyd v. U.S. Postmaster General