The court's take on 'essential' job functions is one every HR team should read
When an employer calls a rule "essential," does that make it so? A federal appeals court just said no.
On June 15, 2026, the Eighth Circuit Court of Appeals revived a disability claim brought by a registered nurse who lost her job over CentraCare Health System's COVID-19 vaccine requirement. For HR teams, the decision maps out the accommodation steps that can land an employer in front of a jury.
Christine Klimek worked for CentraCare from 2008 to 2021. After a workplace injury in 2010, she developed Complex Regional Pain Syndrome, also called Reflex Sympathetic Dystrophy, or RSD - a chronic pain condition. In 2016, when CentraCare required the measles, mumps, and rubella vaccine, she received a permanent medical exemption backed by her doctor.
By 2021, Klimek had moved into a clinical documentation role she performed entirely from home. When CentraCare introduced a COVID-19 vaccine policy, she applied again for a medical exemption. Her provider wrote: "It is not recommended that she get any vaccines due to her RSD."
CentraCare denied the request on October 12, 2021 - "without explanation," the court noted - and again on November 16. On December 16, 2021, it placed her on involuntary unpaid leave, which the court said "effectively ended her employment." Klimek obtained a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) and sued under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act.
A trial court sided with the employer. The appeals court reversed.
The heart of the decision is one HR leaders should not skim past. CentraCare argued that following its vaccine policy - or getting an exemption from it - was an "essential job function." The court rejected that outright: "Adding the label of 'policy' to a task does not render it an essential job function." An exemption, the judges said, is an accommodation, and an accommodation cannot also be an essential function. Vaccination, the court added, was "a means to an end," not the job itself.
The interactive process was the next stumbling block. That is the required back-and-forth between employer and employee over accommodation. The court found CentraCare "admitted that it did not consider Klimek's work-from-home status or the type of work she performed." If an employer needs more medical detail, the court said, it must ask for it.
Then there was CentraCare's own paperwork. Its internal documents listed "working from home" as a possible accommodation for employees with exemptions. Klimek was already working from home, and had been for months.
The court also rejected CentraCare's "undue hardship" defense - the claim that accommodating her would be too burdensome - because it leaned on the chance she might one day be called back to in-person work. Hardship, the judges wrote, "must be sufficiently real rather than speculative."
The practical signals are clear. Denying an exemption without a reason is a risk. Labeling a requirement "essential" without anchoring it to real duties may not survive scrutiny. And if your policy names remote work as an accommodation, be ready to explain why it was not offered.
The case now returns to the district court. The appeals court did not rule that CentraCare broke the law - only that the dispute is real enough to go before a jury.
