The Eighth Circuit Court of Appeals ruled on May 18, 2026, in the case of Angela Kendall v. Zoltek Corporation, affirming the lower court's decision to grant summary judgment in favor of Zoltek. This ruling affects Kendall, who alleged discrimination and failure to accommodate her disability under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act. The court's decision clarifies the standards for proving disability discrimination in the workplace.

Angela Kendall, a former production operator at Zoltek Corporation, filed a lawsuit against her employer after being terminated in January 2022. She claimed that Zoltek failed to accommodate her disability and retaliated against her for asserting her rights under the ADA. The case began when Kendall, who started working for Zoltek in 2018, experienced back pain after slipping at work in April 2021. Although she was initially cleared to return to work, her condition worsened, leading her to request accommodations that included the ability to sit during her shifts.

Kendall's request for accommodations stemmed from her diagnosis of muscle spasms and potential sciatica. Zoltek initially allowed her to sit during her shifts but later insisted that all production operators, including Kendall, needed to stand for the entirety of their 12-hour shifts. After several months of temporary accommodations, Zoltek ultimately placed her on medical leave and later terminated her employment, stating that she could not perform the essential functions of her job.

The dispute escalated as Kendall filed discrimination charges with the Missouri Commission on Human Rights and the Equal Employment Opportunity Commission (EEOC) before taking her case to the U.S. District Court for the Eastern District of Missouri. There, Zoltek filed a motion for summary judgment, which the district court granted, concluding that Kendall was not qualified for her position due to her inability to meet the essential job functions.

The Eighth Circuit, led by Circuit Judge Shepherd, reviewed the case and affirmed the district court's ruling. The court determined that Zoltek was justified in its decision to terminate Kendall's employment because she could not perform the essential functions of her job as a production operator. The court stated, "Zoltek's written job description for a production operator demonstrates that the position is physically demanding and requires standing during the entirety of a 12-hour shift." The court emphasized that standing was an essential function of the job, and Kendall's inability to do so rendered her unqualified.

In its ruling, the court also addressed Kendall's argument that Zoltek's temporary accommodations indicated that standing was not an essential function. The court clarified that an employer's temporary accommodation does not change the essential functions of a job. The opinion stated, "An employer does not concede that a job function is 'non-essential' simply by voluntarily assuming the limited burden associated with a temporary accommodation." This highlights the importance of job descriptions and employer expectations in determining essential job functions.

Furthermore, the court found that Kendall's claims of sex discrimination under Title VII were also unfounded. The court noted that Kendall failed to establish that she was qualified for her position, which is a necessary component of a discrimination claim. The ruling stated, "The minimum objective criteria for production operators required that an individual be able to stand for up to 12 hours, lift more than 25 pounds overhead, bend, and turn, among other physical requirements." Because Kendall could not meet these criteria, her claims were dismissed.

The court's decision has significant implications for employees with disabilities and employers. It reinforces the idea that employers are not required to make accommodations that fundamentally alter the essential functions of a job. This ruling also clarifies the standards for establishing a prima facie case of discrimination under the ADA and Title VII, emphasizing that employees must demonstrate their ability to perform essential job functions to succeed in such claims.

Looking ahead, Kendall's options for appeal are limited, as the Eighth Circuit's decision is typically final unless there are grounds for a rehearing or a petition for review by the U.S. Supreme Court. There are no related cases pending that could impact this ruling directly. However, the case may serve as a reference point for future disability discrimination cases in the Eighth Circuit, shaping how similar claims are evaluated in the workplace.