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Zande v. State of Wisconsin Department of Administration

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In Brief

The 7th Circuit held that an employee’s ulcers were part of her disability and, therefore, the employer had a duty to provide a reasonable accommodation for the ulcers, but that the employer did not need to allow remote work or install a computer in the employee’s home.

What Happened in Court

The seventh circuit held that pressure ulcers caused by an employee’s being paraplegic were part of the employee’s disability because they were “an intermittent impairment that is a characteristic manifestation” of the underlying disability. However, the court determined that the ADA did not require the employer to allow liberal work from home or install a computer in the employee’s home to avoid the employee’s use of sick leave.