The court's take on 'essential' job functions is one every HR team should read

When an employer calls a rule "essential," does that make it so? A federal appeals court just said no.

On June 15, 2026, the Eighth Circuit Court of Appeals revived a disability claim brought by a registered nurse who lost her job over CentraCare Health System's COVID-19 vaccine requirement. For HR teams, the decision maps out the accommodation steps that can land an employer in front of a jury.

Christine Klimek worked for CentraCare from 2008 to 2021. After a workplace injury in 2010, she developed Complex Regional Pain Syndrome, also called Reflex Sympathetic Dystrophy, or RSD - a chronic pain condition. In 2016, when CentraCare required the measles, mumps, and rubella vaccine, she received a permanent medical exemption backed by her doctor.

By 2021, Klimek had moved into a clinical documentation role she performed entirely from home. When CentraCare introduced a COVID-19 vaccine policy, she applied again for a medical exemption. Her provider wrote: "It is not recommended that she get any vaccines due to her RSD."

CentraCare denied the request on October 12, 2021 - "without explanation," the court noted - and again on November 16. On December 16, 2021, it placed her on involuntary unpaid leave, which the court said "effectively ended her employment." Klimek obtained a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) and sued under the Americans with Disabilities Act...

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