On June 26, 2026, the U.S. Court of Appeals for the Third Circuit ruled that a Pennsylvania university did not discriminate against a secretary based on an alleged disability when it denied her request to work remotely as a disability accommodation because the secretary’s position had several in-person job responsibilities.

Quick Hits

• In a nonprecedential ruling, the Third Circuit ruled in favor of Shippensburg University, finding that a secretary’s accommodation request to work remotely due to an alleged disability was unreasonable.
• The court noted that the undisputed facts indicated that the secretary had several in-person job responsibilities.
• This case emphasizes the importance of accurately outlining in-person responsibilities in job descriptions, particularly in the context of ADA accommodation requests.

In a nonprecedential ruling in Sheehan v. Shippensburg University, the Third Circuit upheld a summary judgment in favor of Shippensburg University in a disability discrimination lawsuit filed by a psychology department secretary, alleging violations of the Americans with Disabilities Act (ADA), the Pennsylvania Human Relations Act (PHRA), and the Rehabilitation Act (RA).

The secretary, who had been allowed to work remotely during the 2020 to 2021 school year amid the COVID-19 pandemic, requested to work remotely as an accommodation in December 2021 following the emergence of a new strain of the virus. The university denied the secretary’s accommodation request,...

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