Employees across North Carolina—including Charlotte, Raleigh, Wilmington, Winston-Salem, and Asheville—often assume an ADA case turns on whether the employer “tried hard enough” to accommodate. In practice, many ADA cases turn earlier, on a threshold question: is the employee a “qualified individual” who can perform the job’s essential functions, with or without a reasonable accommodation? The Fourth Circuit’s unpublished decision in Robinson v. Mountaire Farms of North Carolina Corp. is a useful reminder that medical restrictions must be addressed with a specific, functional accommodation plan tied to the essential functions of the job.
This article is written for employees. The goal is to help you build the record needed to succeed on the “qualified individual” element and to strengthen the interactive-process evidence that often matters in litigation.
Overview of the Decision and Its Significance for Employees
The employee in Robinson worked as a “rehang supervisor” in a poultry-processing environment and spent approximately 75–80% of the shift walking the lines. After an off-duty injury, his physician imposed restrictions that included sedentary work, limited standing/walking, required rest breaks, no use of one arm, and strict limits on lifting/pushing/pulling.
The employer evaluated the job’s physical demands and concluded it could not reasonably accommodate the employee in that role and that there were no vacant positions within his restrictions. The Fourth Circuit affirmed summary judgment, holding the employee was not a “qualified individual” because he could not perform the job’s essential functions at the time of termination.
Practical significance for employees: even where there is discussion back and forth, courts will focus on whether the evidence shows you can do the essential functions with a workable accommodation—not just that you need “light duty” or that work is difficult.
Core ADA Issue: “Qualified Individual” and Essential Job Functions
A central lesson of Robinson is that the ADA does not require an employer to retain an employee who cannot perform essential functions, and it does not require the employer to create a new job or an indefinite light-duty role. Where the job is physically demanding and your restrictions conflict with those demands, you must be able to show one of two things:
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You can perform the essential functions with a reasonable accommodation, or
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You can perform another available job and reassignment to a vacant position is a reasonable accommodation.
In Robinson, the evidence pointed the other way: the job required extensive walking/standing, while the medical restrictions materially limited walking/standing and required sedentary work and rest breaks.
Practice Pointers for Employees Seeking to Strengthen an ADA Claim in North Carolina
1. Document the Essential Functions of the Position
Your first objective is to define the essential functions accurately—before the case becomes a dispute about what your job “really” requires.
What to do now
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Request and retain the job description, physical requirements, and any safety/production policies related to your role.
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Keep contemporaneous notes about the job’s actual demands (time standing/walking; lifting; pace/quotas; shift length; environmental constraints).
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Identify which tasks are core and which are marginal. Many accommodation disputes are won or lost on that distinction.
Why it matters
If your restrictions limit an activity that is truly essential, you must pivot to a concrete accommodation or reassignment strategy. If your employer inflates marginal tasks into “essential” ones, your documentation becomes critical rebuttal evidence.
2. Obtain Medical Documentation Framed in Functional Terms
Courts generally respond better to functional limitations than to labels. Your medical documentation should translate your condition into work-relevant capabilities and limits.
How to improve your medical support
Ask your treating provider to document:
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What you can do (not just what you cannot do): maximum standing, walking, lifting, reaching; sitting tolerance; ability to alternate positions.
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Frequency and duration: “stand up to X minutes at a time,” “walk up to Y total hours per shift,” “rest Z minutes every hour.”
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Expected course: anticipated improvement timeline and next evaluation date.
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Accommodation linkage: equipment, posture changes, break schedule, task modifications that enable performance.
Why it matters
A well-crafted functional note allows you (and your counsel) to propose accommodations that map to actual job duties and to show you remain “qualified.”
3. Propose Specific, Workable Accommodations Linked to Essential Functions
Your accommodation request should read like a practical plan an employer can implement—especially in physical or production environments.
Examples of strong, job-linked accommodation requests
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Sit/stand options where feasible (e.g., stool, anti-fatigue mat, adjustable workstation), paired with medical justification.
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Structured break schedule (e.g., “10 minutes seated every hour”), with a plan to maintain productivity/coverage.
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Temporary modification of marginal tasks (not essential functions) during recovery.
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Shift or schedule adjustments tied to fatigue/pain management.
Avoid these common pitfalls
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“I need light duty” with no definition.
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Requests that effectively remove essential functions without a substitute plan.
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Open-ended requests without time horizons or functional thresholds.
Best practice
Put your proposal in writing and be explicit: “With the following accommodations, I can perform the essential functions of my position.”
4. Create a Clear Record of Participation in the Interactive Process
Courts often examine whether the parties engaged in an interactive process with real information exchange. You should assume every email may later be read by a judge.
How to build the right record
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Make the request in writing (email is fine).
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Respond promptly to employer questions and provide updated medical documentation as needed.
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After any meeting, send a short confirmation email summarizing:
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the employer’s stated concerns,
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what medical information was requested, and
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the accommodations you are proposing.
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Why it matters
A clean paper trail helps prevent an employer from later claiming you were unresponsive or refused viable options—and it helps your counsel establish credibility if litigation follows.
5. Use Caution When Advancing “100% Healed” Arguments
Employees often suspect that an employer requires “100% healed” before returning. These arguments can succeed in the right facts, but they are most persuasive when supported by concrete proof that the employer applies such a rule as a policy, not merely as a response to a particular set of restrictions.
If you believe a “100% healed” approach is being applied
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Look for concrete proof: written policy language, HR scripts, standardized emails, or consistent statements across multiple situations.
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Identify comparators: similarly situated employees who were permitted to return with restrictions (or denied despite being qualified).
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Keep the focus on the ADA standard: you are “qualified” if you can perform essential functions with reasonable accommodation.
Why it matters
A “policy” argument without proof can distract from what usually wins cases: showing you are qualified and proposing a workable accommodation.
Conclusion: Positioning an ADA Claim for Success in North Carolina
For North Carolina employees—whether in Charlotte, Raleigh, Wilmington, Winston-Salem, Asheville, or elsewhere—the practical lesson from Robinson is straightforward:
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Define the essential functions accurately;
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Obtain functional, specific medical documentation; and
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Propose reasonable accommodations that preserve your ability to perform essential functions, or identify a vacant role you can perform.
When the evidence shows the restrictions prevent essential functions and there is no workable accommodation or vacant reassignment, courts may dispose of the case on summary judgment.
When to Consult Counsel Regarding an ADA Accommodation Request
Consider speaking with counsel early if:
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your employer is treating restrictions as automatic disqualification,
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the employer is refusing to engage meaningfully, or
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you are being pushed toward termination, forced leave, or resignation while accommodations are still feasible.