Haggins: Unperformed On-Site Duties and Missed Updates Defeated ADA Claims

A temporary full-time remote arrangement changed when business returned and on-site accounting work accumulated. In Haggins v. Wilson Air Center, LLC, No. 24-1010 (4th Cir. Jan. 14, 2026), the Fourth Circuit affirmed summary judgment for the employer on federal ADA discrimination and retaliation claims.

This published Fourth Circuit decision applies federal law to a North Carolina employment record. A California matter requires separate analysis of governing Ninth Circuit law and California’s FEHA. The decision is useful for its detailed examination of job duties, an agreed hybrid arrangement and the communication surrounding a medical absence.

Remote work had shifted physical tasks to a coworker

DeAnne Haggins had worked for Wilson Air for more than 16 years as an accounts-payable employee. Her work included paper checks, mailed invoices and physical supplier files. At the pandemic’s onset, she adopted a hybrid schedule. She moved to full-time remote work in summer 2020 because of her compromised immune system and cancer treatment. Business had fallen sharply, and a coworker handled the physical tasks.

As business recovered in March 2021, those tasks increasingly burdened the coworker. The employer sought a partial return—initially two days a week, with four to five hours in the office each day. Haggins agreed but did not attend as arranged. Further discussions in May produced another flexible hybrid arrangement and medical documentation.

The employer reviewed the duties, offered precautions including masking and a closed office, and directed a return. Haggins attended only two partial days, May 26 and May 28, during the roughly eighty-day period from the initial March request through termination. These facts mattered because the remote arrangement had left essential physical work for someone else.

The June note and update request were decisive facts

Haggins underwent surgery on June 3. She contacted her doctor on June 8; the note was dated June 9 and received by the employer on June 10. It stated that she should remain out until Thursday, June 17. The employer asked for an update on Wednesday, June 16 and expected her return on June 17. She neither supplied the requested update nor appeared on June 17, and the employer terminated her employment for job abandonment.

The court recognized a possible reading of “until” as allowing return after June 17, but found that Haggins failed to clarify it in response to an email identifying June 16 as the final day of absence. That sequence followed repeated attempts to obtain attendance and communication. The court evaluated the actual exchanges, not merely the existence of a serious diagnosis or the fact that a medical note had once been provided. The chronology appears in Haggins.

The essential duties required more than an unperformed agreement

Under 42 U.S.C. section 12111(8), the ADA protects a qualified individual who can perform the job’s essential functions with or without reasonable accommodation. The court considered the employer’s judgment, the paper-based duties and the practical consequences of shifting that work to a coworker as demand returned.

Haggins did not argue on appeal that she could fulfill the job’s essential functions while working entirely from home. She argued that the employer failed to honor a hybrid agreement. The court found the record showed the opposite: The employer kept seeking the agreed partial attendance, while Haggins failed to perform under that arrangement or communicate reliably about absences.

The court also rejected the premise that the earlier temporary reassignment of essential duties required their continued reassignment. Business conditions and the coworker’s workload had changed. The employer’s previous assistance did not establish that the job could permanently be performed without the on-site functions. The qualified-individual analysis is developed in Haggins.

Retaliation required a separate causation analysis

The court recognized that an ADA retaliation claim does not depend on meeting the qualified-individual requirement for the discrimination claim. It therefore examined retaliation separately.

Haggins relied on the timing of her May 17 complaint to human resources about the hybrid-work mandate. The court measured from that complaint, rather than from the earlier denial of full-time remote work. It found the one-month interval, standing alone, insufficient to establish the necessary causal link on this record, particularly given the continuing accommodation efforts. The attendance and communication evidence also supported the employer’s stated explanation.

The discussion turns on the full sequence. Its treatment of the period between the complaint and termination should not be converted into a fixed number of days that establishes or defeats retaliation in every case.

What the record shows someone preparing for a return

A medical note, an agreed schedule and a requested update can address different things. The note may state an expected period of absence; the employer’s message may seek current information before that period ends. Preserve all three documents and explain any inability to respond or return with the supporting evidence.

The judgment was affirmed rather than returned for another accommodation process. For a focused practical discussion of the note and communications, read Your Medical Leave Note Ends This Week: Clarify the Return Date and the Next Update.