Fourth Circuit ruling shows exactly when medical restrictions exceed accommodation requirements
Court affirms termination when worker's medical restrictions made essential job functions impossible, giving employers clearer guidance on accommodation limits.
In a decision dated February 4, 2026, the Fourth Circuit Court of Appeals affirmed that Mountaire Farms of North Carolina acted lawfully when it terminated Craige Robinson, a rehang supervisor who could no longer meet the physical demands of his job after being shot at a cookout in 2021.
Robinson had worked at the chicken processing plant since 2016 and earned a promotion to rehang supervisor two years later. The job was physically demanding. He supervised six production lines, managed staffing, handled administrative tasks, and oversaw the ice house. Most critically, he spent three-quarters of every shift on his feet, walking the floor to keep operations running smoothly. The plant floor had no chairs.
Everything changed on August 29, 2021, when an unknown shooter wounded Robinson at a neighborhood gathering. Bullets struck his elbow and hip, requiring two surgeries and weeks of recovery. The company placed him on family and medical leave.
When his doctor cleared him to return in October 2021, the restrictions were extensive. Robinson could only do seated work. He could not use his left arm at all. His right arm could handle no more than five pounds. The clearance was temporary, pending another evaluation.
Robinson came back to work on October 20, still wearing a brace and in pain. By early November, after exhausting his leave time using vacation days, his doctor imposed even stricter limits. Robinson could stand or walk for just one to four hours daily and needed to sit for fifteen minutes every hour. No ladders. No lifting, pushing, or pulling beyond five pounds.
The company gave Robinson a detailed list of what the supervisor job required. Standing and walking for long stretches. Lifting up to 50 pounds occasionally. Climbing stairs. Working in cold, wet conditions. Managing daily production.
Robinson showed the list to his doctor during a November 22 exam. The doctor revised the restrictions but maintained the severe limitations.
The next day, plant leadership gathered to review the situation. The plant manager, superintendent, and four company directors met to assess whether Robinson could continue in any capacity. Their conclusion was straightforward: the rehang supervisor role could not accommodate someone who needed to sit most of the shift. They also determined no other vacant positions matched his abilities under the medical restrictions.
On November 30, human resources director Pamela Webster delivered the news. Robinson was terminated due to his physical limitations, the exhaustion of his leave, and the lack of suitable openings. The company told him he could reapply if his health improved and reminded him he remained eligible for long-term disability benefits.
Robinson sued, arguing the company violated the Americans with Disabilities Act by failing to accommodate him, wrongfully terminating him, and maintaining an illegal policy that required workers to be completely healed before returning.
The district court sided with Mountaire Farms, granting summary judgment. Robinson appealed.
The Fourth Circuit upheld the decision. The court focused on whether Robinson qualified as a protected individual under the disability law. That designation requires showing you can perform essential job functions, with or without reasonable help.
The appeals court found Robinson could not meet that standard. His doctor restricted him to standing or walking no more than four hours daily. The mismatch was stark. Even Robinson's own testimony confirmed he could not do what the position demanded.
The court also rejected his claim that Mountaire maintained a blanket policy barring anyone with restrictions from working. The evidence showed the company had accommodated other employees when possible and allowed people to return with limitations that did not eliminate core job duties. The company worked extensively with Robinson to explore options. His situation was simply too restrictive.
The opinion offers employers a roadmap. Document essential functions clearly. Engage in genuine dialogue about accommodations. Search for alternative roles. When restrictions make the job impossible, termination can be lawful.
