The Imperative of Documented Medical Justification for Reasonable Accommodations under the Rehabilitation Act

Introduction

The case of Bradley T. Ellerman v. Brooke L. Rollins, United States Secretary of Agriculture, reviewed by the United States Court of Appeals, Seventh Circuit on March 7, 2025, presents a critical examination of the standards for reasonable accommodation requests under the Rehabilitation Act of 1973. Bradley Ellerman, a disabled job applicant from Wisconsin, challenged the U.S. Department of Agriculture's refusal to permit him to telework from his home in Wisconsin. Despite receiving partial offers, Ellerman insisted on avoiding relocation to Kansas City, Missouri, citing his disabilities. The central issues of the case involve:

Whether an applicant must provide concrete, medical evidence linking his disability with the inability to relocate.
The sufficiency of the Department’s interactive process and accommodation offers.
Determining if a reasonable accommodation can be claimed without a detailed evidentiary connection to the disability.

The key parties involved are Bradley Ellerman, the applicant with documented disabilities (a traumatic brain injury, visual impairments, and chronic hip pain), and the U.S. Department of Agriculture, represented by its Secretary, Brooke L. Rollins, as the employer.

Summary of the Judgment

The court affirmed the district court’s summary judgment in favor of the Department. The decision rested on the conclusion that Ellerman failed to provide sufficient medical evidence linking his disabilities to an inability to relocate, thereby failing to demonstrate that his requested accommodation (to work solely from Wisconsin) was reasonable. Although Ellerman submitted medical letters, none directly established that relocation imposed an undue burden due to his disabilities. The court also held that the Department’s alternative accommodation offers—such as partial telework, reimbursement for public transportation costs, and assistive technology—satisfied the interactive process required under the law. As a result, Ellerman’s claim that the Department abandoned this process following his rejection of the proposed accommodations was unavailing.

Analysis

Precedents Cited

The Judgment references several precedents that significantly influenced the court’s decision:

Smithson v. Austin, 86 F.4th 815, 819-20 (7th Cir. 2023): This case was pivotal in interpreting the record in favor of the non-movant (Ellerman) when ambiguities exist. Despite this construction, the court ultimately found that the evidentiary shortcomings in Ellerman's filing outweighed any ambiguity benefits.
Sansone v. Brennan, 917 F.3d 975, 979 & n.1 (7th Cir. 2019): The court relied on this case to confirm that failure-to-accommodate claims under the Rehabilitation Act require proof that the applicant is a qualified individual with a disability, that the employer was aware of the disability, and that the requested accommodation was both necessary and reasonable.
Ellison v. United States Postal Serv., 84 F.4th 750, 756 (7th Cir. 2023): This precedent reinforced the notion that a requested accommodation must be shown as reasonable in its connection to the disability.
Wells v. Winnebago County, 820 F.3d 864, 867 (7th Cir. 2016): This decision underscores the necessity of providing specific medical evidence to support claims that a disability necessitates a particular accommodation.
Ekstrand v. Sch. Dist. of Somerset, 583 F.3d 972, 976-77 (7th Cir. 2009): The case confirmed that an employer is not obligated to satisfy an accommodation request absent evidence directly connecting the accommodation to the disability.

Legal Reasoning

The court’s reasoning centers on establishing a clear evidentiary requirement when an employee claims that a specific accommodation is necessary due to a disability. The key elements forming the legal backdrop are:

Evidence Requirements: Ellerman failed to timely provide robust medical evidence that his disabilities prevented him from relocating. Although he submitted several medical letters attesting to his visual impairments and hip pain, none of these documents directly linked these disabilities to an inability to work outside Wisconsin. This shortfall was critical in the court’s assessment of whether his requested accommodation was reasonable.
Interactive Process: The court noted that a responsive and ongoing dialogue between employer and employee is central to the accommodation process. The Department demonstrated active engagement by offering alternative but reasonable accommodations. The mere fact that Ellerman rejected these alternatives did not constitute evidence of a failure by the employer.
Reasonableness of the Accommodation Request: The ruling clarified that for a reasonable accommodation to be granted, it must be directly tied to the limitations imposed by the disability. Ellerman’s request to work exclusively from Wisconsin—without the requisite medical substantiation that his disabilities prevented him from relocating—did not meet this standard.

Impact

The Judgment has significant implications for future reasonable accommodation cases under the Rehabilitation Act and similar statutes:

Stricter Evidentiary Burden: Employers may now be more confident in requesting corroborative medical documentation that establishes a clear nexus between a disability and the need for a specific accommodation. Future litigants must address this evidentiary burden early in the accommodation request process.
Clarification of the Interactive Process: The decision reaffirms that even if some breakdown in the interactive process occurs, it does not independently form the basis for legal liability unless the accommodation request itself is shown to be reasonable and properly substantiated.
Guidance for Employers: Government agencies and private employers alike now have strengthened legal backing to provide alternative accommodations when an applicant’s primary request lacks the necessary evidentiary support.

Complex Concepts Simplified

To aid understanding, several complex legal concepts from the Judgment are explained below:

Reasonable Accommodation: Modifications or adjustments to a job or work environment that enable a qualified person with a disability to perform essential functions. The accommodation must be practical without imposing undue hardship on the employer.
Interactive Process: A collaborative discussion between the employer and the employee to identify feasible accommodations that meet the employee’s needs while considering the employer's constraints.
Evidentiary Burden: The requirement for the employee to provide proof that a particular accommodation is directly linked to the effects of their disability.

Conclusion

In sum, the Judgment in Bradley T. Ellerman v. Brooke L. Rollins reinforces the principle that a reasonable accommodation request must be supported by specific and timely medical evidence directly linking the accommodation to the disability. While the Department of Agriculture engaged in an appropriate interactive process and proposed workable alternatives, Ellerman’s failure to substantiate his claim of an inability to relocate ultimately precluded his claim from surviving summary judgment. This ruling establishes a crucial precedent: employees seeking accommodations must clearly demonstrate how their disabilities necessitate the requested modifications, thereby underscoring the importance of documented medical justification in such claims.

The decision not only clarifies the evidentiary requirements in accommodation claims under the Rehabilitation Act but also provides guidance for employers on navigating the interactive process effectively. As future cases arise, this Judgment is likely to serve as a reference point for courts in evaluating the reasonableness and substantiation of accommodation requests.