An employee was not entitled to work entirely from a home office as an accommodation under the Americans with Disabilities Act (ADA) because the central components of her job required her to work on the employer's site, ruled the 7th U.S. Circuit Court of Appeals.

Beverly Rauen was employed as a software engineer by United States Tobacco (UST). Her primary duties involved monitoring contractors' work at one of the employer's facilities. During the late 1990s, Rauen suffered successive bouts of rectal and breast cancer. During each period of illness she went on short- and long-term disability leave and ultimately returned to work in January 1999.

Upon her return to work, Rauen asked to work from a home office because her sickness and treatments caused her extreme fatigue and required very frequent restroom use as well as ostomy care.

UST offered to let her work from home most days, but to come into the office one day per week. Rauen rejected this and other proposed accommodations.

Rauen continued to work full-time, filed a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC) and, ultimately, filed suit against UST. The trial court dismissed the case, finding that, because Rauen could perform the essential functions of her job without accommodation, she was not entitled to any accommodation at all.

The 7th Circuit declined to decide the question of whether any accommodation is reasonable for a person who can perform all the functions of her job. Rather, the court more narrowly ruled that Rauen's specific requested accommodation was not the "very extraordinary" case where a home office would be reasonable. Her main duties required "teamwork, interaction and coordination of the type that requires being in the work place," the court said. That she could perform all the essential functions of her job without accommodation further tipped the balance away from the reasonableness of her request.