## Facts

- Lori L. Vande Zande, a paraplegic wheelchair user, worked as a program assistant performing clerical and administrative tasks for the Wisconsin Department of Administration.
- During a period of pressure ulcers associated with prolonged wheelchair use, she needed time at home to heal.
- The Department permitted her to work some hours from home temporarily but declined to buy an additional computer to support a full-time, routine work-from-home arrangement.
- Vande Zande used sick leave for time she did not work while healing and claimed the refusal to fund full-time home work was a failure to reasonably accommodate.
- She also sought structural changes to office kitchenettes that were not fully wheelchair-accessible.
- The Department made various workplace modifications affecting access (including adjustments to doors, restrooms, and workspace) and considered additional changes to kitchenettes.
- For certain kitchenette functions, the Department suggested use of a nearby accessible bathroom sink as an alternative.
- Vande Zande alleged discriminatory treatment and a pattern of insensitivity; the record reflected ongoing efforts to accommodate, with disputes centered on the extent of additional measures.

## Issues

1. Whether the employer failed to provide reasonable accommodation under Title I of the ADA by refusing to provide equipment and permission for full-time, routine work from home.
2. Whether the employer failed to provide reasonable accommodation by declining additional structural modifications to kitchenettes where alternative access was available.
3. How “reasonable accommodation” and “undue hardship” limit an employer’s duty to modify job conditions and workplace facilities.

## Decision

- The Seventh Circuit affirmed summary judgment for the employer.
- The court held the Department provided reasonable accommodations and the ADA did not require the additional requested measures.
- The court concluded the ADA did not obligate the employer to convert the job into a permanent at-home position or to purchase duplicative equipment for that purpose on this record.
- The court held the ADA did not require costly structural modifications producing only small incremental benefits when workable alternatives provided effective access.
- The court rejected the claim that the record showed actionable hostility or discriminatory animus, finding evidence of good-faith accommodation efforts.

## Legal Principles

- The ADA’s accommodation duty is satisfied when an employer does what is necessary to enable an otherwise qualified employee with a disability to work in reasonable comfort, absent undue hardship.
- “Reasonable accommodation” is proportional and cost-sensitive; it is a modest requirement and does not compel an employer to provide the employee’s preferred or most effective accommodation.
- An employer is not required to eliminate all work disruptions associated with disability (including the need for some sick leave) if the accommodation provided is reasonable.
- Routine, full-time telework is not generally required where the job reasonably involves supervision, coordination, or teamwork and home work would impair performance or administration.
- For workplace features and amenities, the ADA requires effective, meaningful access rather than identical experiences; large expenditures are not required for trivial or marginal improvements when practical alternatives exist.

## Conclusion

The Seventh Circuit held that the ADA requires practical, proportional accommodations that provide effective access and enable work performance, but it does not require permanent telework arrangements or substantial facility remodeling when the employer has made significant accommodations and reasonable alternatives meet the employee’s functional needs.


Vande Zande v. Wis. Dep’t of Admin., 44 F.3d 538 (7th Cir. 1995)