Labor & Employment Law Daily Wrap Up, DISCRIMINATION—DISABILITY—C.D. Ill.: Training essential function of drivers facility manager who sought COVID-19 accommodation, (Jan 21, 2026)

By Todd Harrison, J.D.

Due to a medical condition, she requested that a distance of at least six feet be kept between her and others, however only her job description contained training obligations.

Granting summary judgment against the ADA discrimination claims asserted by a drivers facility manager for the state of Illinois, a federal district court determined that training duties were an essential function of the position. Even accepting the employee’s contention that others in her office were capable of conducting training did not measurably impact the essential function analysis, as an employer need not reallocate the essential functions of a job that a qualified individual must perform (Helton v. Illinois Secretary of State, No. 23-CV-2036 (C.D. Ill. Jan. 20, 2026)).

During the relevant time period, the employee worked at a driver services office in Monticello, Illinois. She held the job title of Drivers Facility Manager I and was the only drivers facility manager at the Monticello office.

Job description. The job description for the employee’s position states, among other things, that the person holding such a position “provides, arranges for and/or supervises the training of employees as directed or needed.”

Training duties. According to the employee, prior to the onset of the COVID-19 pandemic, she conducted training on a daily basis. She agreed that no one in the office had training obligations outlined in their job descriptions, but she believed that the provision allowing her to “arrange” training meant that she could require subordinates to train other employees, even if those duties were not part of their job description. She asserted that the “union book” stated senior employees are allowed to train other employees if requested. Because she occupied a managerial position, the employee was not a member of the union.

Performance concerns. In March 2020, the employee raised concerns with her superiors regarding the performance of a coworker. The employee was instructed to provide her coworker with remedial training. Such training could not be provided without the employee coming within six feet of her coworker. Nevertheless, on occasions where it was absolutely necessary, the employee came within six feet of the coworker in the spring and summer of 2020.

Medical condition. At some point, the employee talked again with her superiors about the training. After this conversation, the employee requested that her doctor inform the employer of her medical condition—atrial fibrillation.

Accommodation request. On September 1, 2020, the employee’s cardiologist wrote a letter to the employer asking it to excuse the employee from “close contact or training other employees to avoid the Covid 19 infection.” After the employer requested additional information, the employee submitted a request for a reasonable accommodation, stating in part that she was able to perform all essential functions of her job except exposure to infection, such as germs, bacteria, and viruses. In response, the employer stated that it could not guarantee an environment devoid of germs, bacteria, or viruses, and gave the employee the option of applying for a leave of absence or submitting her resignation.

At the end of September, the employee submitted forms requesting sporadic FMLA leave. On October 5, the employer acknowledged receipt of the request but observed that it did not mention the concerns regarding germs, bacteria, or viruses. The employer reiterated that in the absence of new medical documentation, the employee could not return to work and would have to request a leave of absence.

Reinstatement request. On November 20, the employer sent a letter to an attorney retained by the employee responding to a request that the employee be reinstated. The employer explained that regardless of the employee’s request to have someone train others in her absence, her job status was in question due to her doctor’s order that she not have close contact with any coworkers or customers.

Return to work. Through her counsel, the employee submitted a letter from her doctor dated January 21, 2021, clearing her to return to work and allowing her to be in close contact with others for limited periods of time. The letter stated that once she had received the COVID vaccine, these restrictions could be lifted. The employer demanded further information on what constituted “limited periods of time.” Ultimately, she returned to work on March 24, 2021, after getting fully vaccinated.

ADA claims. Subsequently, the employee brought three discrete claims under the ADA: (1) she was denied the reasonable accommodation of not having to train employees; (2) she was discriminated against on the basis of her disability when she was forced to take a leave of absence; and (3) she was discriminated against again when she was not allowed to return to work immediately after the January 21 physician’s letter.

Essential function. First, the court noted that most of the relevant factors identified by the Seventh Circuit supported the conclusion that training employees was an essential function of the employee’s position. Indeed, observed the court, the employee herself believed that training was an essential function of her job.

Daily basis. As for the amount of time spent performing the function, the employee testified that she engaged in training on a daily basis. “Unquestionably, tasks performed on a daily basis are more likely to be regarded as essential,” said the court.

No training obligations. With regard to the employee’s job description, the employer highlighted that training of other employees is expressly contemplated as part of the employee’s duties. The employee argued that the description “does not indicate that she is personally required to provide training for employees. What it states is she is to ‘arrange for and/or supervise the training of employees.’” However, the court noted that the employee omitted the word “provides” from the job description, and the employee testified herself that she provided training to others on a regular basis.

Aside from the employee’s own interpretation of her job description, the court found it relevant that no training obligations appeared in the job descriptions of anyone else who worked in the Monticello office.

“The importance of training in any workplace is self-evident, and the fact that training obligations did not appear in the job description of any other Monticello office employee tends to suggest it was an essential function of Plaintiff’s position,” said the court.

No replacement. Among the factors guiding an essential function analysis, the only one the court found for which the employee had any favorable evidence was the consequences for not requiring her to perform her training duties. The employee pointed out that after she was forced to take a leave of absence, she was not replaced with anyone who stepped in to train her coworker. However, the employer observed that it was “entirely unclear” how the employee would have personal knowledge of what happened at the office during her absence, a point that the court acknowledged was well-taken.

Even if the employee’s statement that no one replaced her in her absence was admissible, the court noted the paradoxical nature of such an argument. The fact that the coworker—who apparently was in great need of training—was not trained during the employee’s leave of absence only served to underscore how essential the employee was to performing that task.

Other job functions. Finally, the employer argued that in addition to her training obligations, the employee was unable to perform other essential functions of her job while maintaining a distance of at least six feet, including interactions with the public and the administration of driver examinations.

Other options. In response, the employee contended that at least two other individuals in the office could have provided training and the collective bargaining agreement specifically permitted this to occur.

As an initial matter, the court found the CBA did not constitute reliable evidence from which any reasonable inferences could be drawn. Even so, setting aside the CBA, the court accepted that others in the Monticello office were capable of conducting training. However, that did not meaningfully change the court’s essential function analysis, as employers are not required to reallocate the essential duties of an employee’s job.

It was undisputed that the employee was medically unable to perform the essential functions of her job and thus was not a qualified individual for ADA purposes, explained the court. Accordingly, the employer’s motion for summary judgment was granted.

The case is No. 23-CV-2036.

Judge: Bruce, C.

Attorneys: John A. Baker (Baker Baker & Krajewski) for Sara Helton. James McCarron, Illinois Attorney General, for Illinois Secretary of State.

Cases: Discrimination DisabilityDiscrimination EmployeeLeave PublicEmployees Covid19 IllinoisNews