The Tenth Circuit in Hennagir v. Department of Corrections recently affirmed the District Court’s grant of summary judgment on an employment accommodation claim.

Barbara Hennagir was employed as a physician’s assistant by the Department of Corrections (DOC). Following several years of successful work by Hennagir, the DOC added a physical safety training requirement to medical and clinical positions that required inmate contact, including Hennagir’s position. Unable to complete the training because of a number of physical impairments, Hennagir complained of disability discrimination and requested that she be able to continue in her position without fulfilling the new requirement. The DOC refused, and suit was initiated by Hennagir.

The District Court granted summary judgment in favor of the defendant on all of Hennagir’s claims. On appeal, Hennagir argued as one of her issues that the DOC failed to reasonably accommodate her inability to become Peace Officer Standard in Training (POST) certified.

The court found that POST certification was an essential job function, yet each of the accommodations proposed by Hennagir demanded an identical modification: waiver of the POST certification requirement. Because Hennagir was requesting that the DOC eliminate an essential job function, she failed to show that a reasonable accommodation was possible. Thus, the Tenth Circuit Court of Appeals concluded that the District Court was correct in entering summary judgment on Hennagir’s reasonable accommodation claim.

Pat McGrath