A new Eleventh Circuit decision, Mundt v. Sheriff, Okaloosa County, reinforces several key principles under the Americans with Disabilities Act (ADA) that employers across the country—including those in California covered by the Fair Employment and Housing Act (FEHA)—should revisit.

In Mundt, the Appeals Court affirmed summary judgment for the employer, rejecting an employee’s disability discrimination claim because he could not perform the essential functions of his job and did not show he was denied a reasonable accommodation.

For employers, the case is another confirmation that essential job functions, clear medical documentation, and a real interactive process remain the core of preventing disability-related claims.

What Happened?

Brandon Mundt worked for the Okaloosa County Sheriff’s Office in a position that required regular physical activity, direct interaction with inmates and the public, and the ability to respond quickly to emergencies. Like many public-safety roles, the essential functions of his job were tied to physical readiness, situational awareness, and the ability to perform safety-critical tasks without limitation. After experiencing medical issues, Mundt submitted restrictions that significantly affected his ability to perform several of these core duties. Over time, he provided multiple medical notes, but the information was often inconsistent or failed to clarify whether—and under what circumstances—he could safely resume the essential demands of his role.

The Sheriff’s Office engaged with Mundt to understand his limitations and evaluate whether any reasonable accommodation would allow him to continue working. The agency reviewed his medical updates, considered potential modifications, and analyzed whether light duty or reassignment were feasible options. Ultimately, the Sheriff’s Office concluded that no accommodation would allow Mundt to perform the essential functions of his job safely and consistently.

Mundt disagreed and sued, claiming that the Sheriff’s Office failed to accommodate him and discriminated against him based on disability. The district court granted summary judgment in favor of the Sheriff, finding that Mundt could not meet his burden, and the Eleventh Circuit affirmed. The Court emphasized that the employer acted lawfully because the law does not require employers to eliminate essential duties, create new positions, or offer indefinitely modified assignments when the employee is unable to perform the core functions of the job.

So What?

The Mundt decision reinforces several practical rules that every employer should keep top of mind.

1. Essential Job Functions are the Foundation of Every Disability Case

The Court emphasized that Mundt could not perform the essential functions of his position, even with an accommodation. That fact alone defeated his claim.

This is a critical reminder: If an employee cannot perform the essential job functions, the employer is not required to retain or accommodate them.

But this protection only works if employers maintain:

• accurate, updated job descriptions
• clear documentation of physical and operational requirements
• consistent enforcement of essential duties

For physical jobs—like in Mundt—physical abilities and safety-related duties are almost always essential.

2. Employees Must Identify a Reasonable Accommodation

The Eleventh Circuit confirmed that to prevail on a disability claim, plaintiffs must show that (1) a reasonable accommodation existed, and (2) the employer failed to provide it. Mundt could not do so.

California law requires the same showing. Employers are not required to:

• create a new position
• provide indefinite light duty
• permanently reassign essential tasks to coworkers
• accept vague or unsupported medical restrictions

The burden is on the employee to identify a feasible accommodation.

3. Medical Documentation Matters

The Court’s reasoning regarding Mundt’s medical documentation is consistent with a common theme in these cases: employees must provide medical documentation that clearly explains what they can and cannot do. It is not enough for the healthcare provider to simply dictate the accommodations the employee wants.

In addition, employers are entitled to request clarification or additional information if they do not have sufficient information to fully evaluate potential accommodations. If the employee does not provide it, the employer is not required to guess.

4. The Interactive Process Still Protects Employers Who Engage in It

The Eleventh Circuit recognized that employers who attempt to engage in the interactive process—and can show it through documentation—are strongly positioned to win disability-related cases.

In Mundt, the Sheriff’s Office:

• communicated with the employee
• reviewed his restrictions
• evaluated possible accommodations
• documented its analysis

That record allowed the Court to affirm the lower court’s dismissal of the case.

Of course, California employers are held to an even higher standard under FEHA, making documentation indispensable.

What Now?

Cases like Mundt serve as a good reminder to revisit your practices:

• Review job descriptions for accuracy and clarity, focusing on essential functions.
• Train supervisors on how to identify accommodation requests and loop in HR early.
• Standardize forms and procedures for requesting medical documentation.
• Document each step of the interactive process, including employee non-participation.
• Ensure light-duty programs are applied consistently—and not treated as permanent accommodations, and do not provide them only to employees with workers’ compensation claims.
• Evaluate leave requests and avoid open-ended, indefinite extensions without medical support.

With 2026 bringing new California FEHA and leave-law expansions, this project should be at the top of your “to do” list!

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If you want to get more comfortable with the disability accommodation process, we’d love to have you join us for one of our in-depth Shaw Law Group workshops. Stay tuned for our upcoming classes where we will offer a great introductory session for those just getting started, and an advanced program for HR professionals who want hands-on guidance with the tougher issues. Jen Shaw leads each full-day session, breaking down the law in plain English and sharing practical tools you can use right away to navigate the interactive process—and avoid unnecessary claims. 

About Shaw Law Group 

At Shaw Law Group, we do more than practice employment law—we partner with employers to build compliant, respectful, and productive workplaces. From day-to-day advice and counsel to impartial workplace investigations, proactive HR audits, dynamic training programs, and sensitive pre-litigation matters, our experienced team helps clients stay ahead of the curve—and out of court.