The U.S. Court of Appeals for the Third Circuit affirmed a district court's grant of summary judgment in favor of the federal government in a disability discrimination case involving a former FBI employee. The court issued the non-precedential opinion on Feb. 4, 2026, in *Allepichian B. Aldrich v. Attorney General of the United States of America*.
Allepichian Aldrich, a paraplegic who requires continual use of a wheelchair, worked as a forensic accountant at the FBI from February 2022 to July 2022. Following her resignation, Aldrich filed claims against the Attorney General alleging disability discrimination, failure to accommodate, hostile work environment, constructive discharge, and retaliation under the Rehabilitation Act and the Americans With Disabilities Act.
The case originated in the U.S. District Court for the Eastern District of Pennsylvania, where Judge Paul Diamond presided. The district court granted the federal government's motion for summary judgment, effectively dismissing Aldrich's claims before trial.
In the Third Circuit appeal, a three-judge panel consisting of Chief Judge Michael Chagares and Circuit Judges Tamika Montgomery-Reeves and L. Felipe Restrepo heard the case. Circuit Judge Stephanos Bibas wrote the brief opinion affirming the lower court's ruling.
The appeals court noted that it assumed the parties' familiarity with the underlying facts, procedural history, and issues on appeal, indicating the court focused primarily on legal questions rather than factual disputes. This approach is typical in appeals courts, which generally review lower court decisions for legal errors rather than re-examining factual findings.
The district court had correctly observed that, as a practical matter, the defendant in the case is the United States government, despite being styled as the Attorney General. This distinction is important in federal employment discrimination cases, as it affects both jurisdiction and the applicable legal standards.
The federal government had filed a motion to dismiss or, alternatively, for summary judgment in the district court. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. The district court's grant of this motion suggests that either the legal claims were deficient or that undisputed facts did not support Aldrich's allegations.
The Rehabilitation Act of 1973 prohibits disability discrimination by federal agencies and requires reasonable accommodations for qualified individuals with disabilities. The Americans With Disabilities Act provides similar protections in the private sector and was extended to certain federal government activities through subsequent amendments.
For federal employees like Aldrich, the Rehabilitation Act serves as the primary vehicle for challenging disability discrimination. Successful claims typically require showing that the employee has a qualifying disability, was otherwise qualified for the position, and faced discrimination because of the disability. Failure to accommodate claims require evidence that the employer failed to provide reasonable accommodations that would have enabled the employee to perform essential job functions.
Hostile work environment claims under disability laws parallel those under other civil rights statutes, requiring evidence of severe or pervasive conduct that creates an abusive work atmosphere. Constructive discharge occurs when working conditions become so intolerable that a reasonable person would feel compelled to resign. Retaliation claims require proof that an employee faced adverse action for engaging in protected activity, such as requesting accommodations or filing discrimination complaints.
The Third Circuit's decision to issue a non-precedential opinion means the ruling will not serve as binding precedent for future cases. However, the affirmance suggests that the appeals court found no legal error in the district court's analysis or conclusion that the federal government was entitled to judgment as a matter of law.
The case was submitted under Third Circuit Local Appellate Rule 34.1(a) on Dec. 5, 2025, indicating it was decided without oral argument. This procedure is often used for cases where the legal issues are straightforward or where the outcome appears clear based on the written submissions.
The ruling represents another challenge for federal employees seeking to vindicate disability rights in the workplace. While the specific reasons for the affirmance are not detailed in the available portion of the opinion, the outcome suggests that Aldrich faced significant legal hurdles in establishing her claims.
Federal employment discrimination cases often present unique procedural and substantive challenges. Unlike private sector cases, federal employees must navigate specific administrative procedures and face potential sovereign immunity issues. The government also benefits from qualified immunity in certain contexts and may have stronger defenses available.
For disability rights advocates, the case highlights ongoing challenges in federal employment discrimination litigation. Despite statutory protections, plaintiffs must meet demanding legal standards and overcome procedural hurdles that can make successful outcomes difficult to achieve.
The decision comes as federal agencies continue to face scrutiny over their handling of disability accommodation requests and workplace discrimination issues. The case underscores the importance of thorough documentation and legal strategy in pursuing disability discrimination claims against federal employers.