Talisha Rosen-Kellogg v. Kristi Noem

CourtCourt of Appeals for the D.C. Circuit
DecidedJuly 1, 2025
Docket24-5158
StatusUnpublished

This text of Talisha Rosen-Kellogg v. Kristi Noem (Talisha Rosen-Kellogg v. Kristi Noem) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Talisha Rosen-Kellogg v. Kristi Noem, (D.C. Cir. 2025).

Opinion

United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT

No. 24-5158 September Term, 2024 FILED ON: JULY 1, 2025 TALISHA L. ROSEN-KELLOGG, APPELLANT

v.

KRISTI NOEM, SECRETARY, UNITED STATES DEPARTMENT OF HOMELAND SECURITY, APPELLEE

Appeal from the United States District Court for the District of Columbia (No. 1:22-cv-03028)

Before: HENDERSON, KATSAS and RAO, Circuit Judges.

JUDGMENT

The Court has considered this appeal on the record from the District Court for the District of Columbia and on the parties’ briefs. The Court has accorded the issues full consideration and has determined they do not warrant a published opinion. See Fed. R. App. P. 36; D.C. Cir. R. 36(d). It is ORDERED that the judgment of the district court be AFFIRMED. I The Rehabilitation Act prohibits government agencies from discriminating against qualified individuals with disabilities. 29 U.S.C. § 794(a). The Act borrows enforcement provisions from Title VI of the Civil Rights Act, which include an implied private cause of action. Id. § 794a; see Cummings v. Premier Rehab Keller, P.L.L.C., 596 U.S. 212, 218 (2022). The Rehabilitation Act also borrows substantive standards from the Americans with Disabilities Act. See 29 U.S.C. § 794(d). As relevant here, those standards prohibit disability-based discrimination in the terms and conditions of employment, 42 U.S.C. § 12112(a); require employers to make reasonable accommodations for qualified disabled individuals, id. § 12112(b)(5)(A); and prohibit retaliation for ADA-protected activity, id. § 12203(a). II From August 2011 through December 2021, Talisha Rosen-Kellogg worked for the Department of Homeland Security. Rosen-Kellogg suffers from various disabilities: degenerative disc disease, migraines, depression, and post-traumatic stress disorder. DHS accommodated Rosen-Kellogg by allowing her to work remotely. It also gave her a cell phone, which Rosen- Kellogg asserts was related to her remote-work accommodation. At some point during her tenure, Rosen-Kellogg complained that her manager was monitoring her work attendance via Skype. DHS later took away Rosen-Kellogg’s cell phone. Coworkers also began to gossip about how Rosen-Kellogg spent her time. DHS became suspicious and investigated. It found that Rosen-Kellogg had been working remotely from her second home, double-dipping as a real estate broker, and using government equipment in connection with her real estate business. Rosen-Kellogg denied none of this. Instead, she argued that her real estate dealings complied with agency policy and that her second home provided a more relaxed atmosphere for managing her disabilities. DHS fired her. Rosen-Kellogg sued. She alleged that DHS denied her a reasonable accommodation when it took away her cell phone. She also alleged that DHS engaged in disability discrimination by using Skype to monitor her work attendance and by firing her. And she alleged that DHS retaliated against her by harassing, investigating, and firing her because she complained about these supposed instances of discrimination. The district court dismissed these claims for failure to state a claim and denied Rosen-Kellogg leave to amend. Rosen-Kellogg then filed a motion to alter or amend the judgment, which the district court also denied. III We start with the dismissal for failure to state a claim, which we review de novo. Payne v. Salazar, 619 F.3d 56, 59 (D.C. Cir. 2010). A Rosen-Kellogg first claims that DHS unlawfully denied her an accommodation for her disability. The Rehabilitation Act requires employers to make reasonable accommodations for qualified disabled individuals. See 29 U.S.C. § 794(d); 42 U.S.C. § 12112(b)(5)(A). To state a reasonable-accommodation claim, a plaintiff must allege that (i) she was disabled; (ii) her employer had notice of the disability; (iii) she was able to perform the essential functions of her job with a reasonable accommodation for the disability; and (iv) the employer denied her request for that accommodation. Solomon v. Vilsack, 763 F.3d 1, 9 (D.C. Cir. 2014). The dispute here centers on the fourth prong—in particular, whether DHS denied Rosen-Kellogg a reasonable accommodation when it took away her cell phone. An employer is not required to provide an employee with any requested accommodation; it “need only provide some reasonable accommodation.” Aka v. Wash. Hosp. Ctr., 156 F.3d 1284, 1305 (D.C. Cir. 1998) (cleaned up). As relevant here, a reasonable accommodation is one that enables a qualified individual to “perform the essential functions” of her position. 29 C.F.R. § 1630.2(o)(1)(ii). DHS accommodated Rosen-Kellogg’s disabilities by allowing her to work remotely. Rosen-Kellogg contends that she needed a cell phone to work remotely. But there are many tools that might have enabled her to work from home—including the computer software that she was provided—and the complaint does not explain why other tools would not have sufficed. Moreover, the record suggests that Rosen-Kellogg suffered only trivial harms from the loss of her phone. For example, she protests that, without a cell phone, she had to log into her computer to post an “out of office” email. J.A. 62. Her reasonable-accommodation claim is therefore implausible. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

2 B Rosen-Kellogg next alleges that DHS discriminated against her because of her disability. The Rehabilitation Act prohibits employers from discriminating against a qualified individual “solely by reason of” her disability. 29 U.S.C. § 794(a); see also id. § 794(d); 42 U.S.C. § 12112(a). To state a discrimination claim, a plaintiff must allege that she suffered an adverse employment action because of her disability. Waggel v. George Washington Univ., 957 F.3d 1364, 1373 (D.C. Cir. 2020). Rosen-Kellogg argues that, because of her disability, DHS monitored her attendance on Skype and fired her. Neither allegation supports her claim. The monitoring allegation does not involve an adverse employment action, which is one that causes “some harm.” Muldrow v. City of St. Louis, 601 U.S. 346, 354–55 (2024). Monitoring work attendance does not cause the employee any cognizable harm. See Rattigan v. Gonzales, 503 F. Supp. 2d 56, 72–73 (D.D.C. 2007) (collecting cases). On appeal, Rosen-Kellogg contends that other, similarly situated employees were not subject to monitoring.

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Talisha Rosen-Kellogg v. Kristi Noem, Counsel Stack Legal Research, https://law.counselstack.com/opinion/talisha-rosen-kellogg-v-kristi-noem-cadc-2025.