Vande Zande v. State of Wisconsin Department of Administration
United States Court of Appeals for the Seventh Circuit
44 F.3d 538 (7th Cir. 1995)
Vande Zande (plaintiff), paralyzed from the waist down, worked for the Wisconsin housing division (defendant), which accommodated her paralysis with modified facilities, adjustable furniture, a cot, and schedule flexibility; when a severe bout of pressure ulcers (a periodic manifestation of her underlying paralysis) required an eight-week absence, she successfully worked from home for all but 16.5 hours (covered by sick leave) after the Department denied her request for a home desktop computer. She sued under the ADA, also complaining the Department failed to lower break-room sinks and counters by two inches; the district court granted the Department summary judgment, and Vande Zande appealed.
Whether, under the Americans with Disabilities Act, employers have a duty to reasonably accommodate intermittent or episodic manifestations of an employee's underlying, chronic disability.