The Fourth Circuit Court of Appeals affirmed Tuesday a district court's dismissal of a disability discrimination lawsuit against Wilson Air Center, LLC, finding that the aviation services provider went beyond legal requirements in accommodating an employee with breast cancer during the COVID-19 pandemic.
In *Haggins v. Wilson Air Center, LLC* (4th Cir. 2026), the appeals court upheld the lower court's ruling in favor of the company in a case brought by DeAnne M. Hall Haggins, who claimed her termination violated the Americans with Disabilities Act.
The case arose when Haggins, diagnosed with breast cancer during the pandemic, sought workplace accommodations from Wilson Air Center, a private aviation services provider. According to the Fourth Circuit opinion written by Judge Wilkinson, the company initially allowed Haggins to work full-time from home when business was down during the early pandemic period, continuing to pay her full salary.
As Wilson Air's business rebounded, however, the company sought to implement a hybrid work schedule that would require Haggins to return to the office part-time. The court noted that in-person duties Haggins had previously shifted to a colleague were beginning to overwhelm that employee, necessitating her partial return to office work.
While Haggins agreed to the hybrid arrangement in writing, the court found she resisted the schedule in practice. After she repeatedly missed work without notice, Wilson Air discharged her employment. Haggins subsequently filed suit claiming discrimination and retaliation under the ADA.
The Fourth Circuit panel, consisting of Judges Wilkinson, Agee, and Thacker, unanimously affirmed the district court's ruling. Judge Wilkinson wrote that given the circumstances, "both compassion and real efforts at accommodation were called for," but concluded that "far from breaking the law, Wilson Air exceeded the call of duty."
The court emphasized that Wilson Air had allowed Haggins to work full-time from home when business conditions permitted, maintaining her full salary throughout that period. The opinion noted that the eventual return of business necessitated at least a part-time return to office duties.
The case highlights the complex balancing act employers faced during the pandemic between accommodating employees with health conditions and maintaining business operations as conditions changed. The court's analysis focused on whether Wilson Air provided reasonable accommodations under the ADA and whether the company's actions constituted unlawful discrimination or retaliation.
The Fourth Circuit's decision provides guidance for employers navigating disability accommodation requests in evolving business circumstances. The court's finding that Wilson Air "exceeded the call of duty" suggests that employers who make good-faith efforts to accommodate employees beyond minimum legal requirements may receive favorable treatment from courts, even when business needs ultimately require changes to those accommodations.
The case was argued before the Fourth Circuit on Dec. 11, 2025, and decided Jan. 14, 2026. The appeal originated from the U.S. District Court for the Western District of North Carolina in Charlotte, where District Judge Robert J. Conrad Jr. initially ruled in favor of Wilson Air Center.
Ralph Thomas Bryant Jr. of the Ralph Bryant Law Firm in Greenville, North Carolina, represented Haggins on appeal. Wilson Air Center was represented by Proloy K. Das of FordHarrison LLP in Hartford, Connecticut, with Frank L. Day of FordHarrison's Memphis office also on the brief.
The decision joins a growing body of case law addressing how disability accommodation requirements apply in remote work and hybrid work situations that became commonplace during the pandemic. Courts have generally required employers to engage in the interactive process with employees requesting accommodations while recognizing that business necessity can justify certain workplace requirements.
For aviation industry employers specifically, the ruling may provide reassurance that courts will consider the operational realities of businesses that require in-person presence for certain functions. The Fourth Circuit's emphasis on Wilson Air's initial accommodation efforts suggests that employers who demonstrate flexibility and good faith in the accommodation process may receive favorable consideration even when circumstances later require changes.
The case also underscores the importance for employees to comply with agreed-upon accommodation arrangements. The court's finding that Haggins "resisted in practice" despite agreeing to the hybrid schedule "on paper" appears to have influenced the outcome, particularly given her subsequent pattern of missing work without notice.
As employers continue to navigate post-pandemic workplace arrangements and accommodation requests, the Fourth Circuit's decision in *Haggins* provides a framework for analyzing when employer efforts meet or exceed ADA requirements, even in challenging circumstances involving employee health conditions and changing business needs.