151584P.pdf   10/17/2016  Roberta Kowitz  v.  Trinity Health
   U.S. Court of Appeals Case No:  15-1584
   U.S. District Court for the District of North Dakota - Bismarck   
   [PUBLISHED] [Kelly, Author, with Riley, Chief Judge, and Colloton, Circuit 
   Judge] 
   Civil case - Employment Discrimination. Plaintiff produced sufficient 
   evidence to raise a genuine issue of material fact as to whether she 
   requested an accommodation; while she did not request an accommodation in 
   so many words, there was evidence from which a jury could find that 
   defendant should have understood or did understand plaintiff's written and 
   oral communications concerning her condition - that she would be unable to 
   complete the basic life support certification without medical clearance 
   and that she required four months of physical therapy before completing 
   the certification - to be a request for a reasonable accommodation; this 
   was sufficient to trigger defendant's duty to engage in the interactive 
   process of identifying a reasonable accommodation, and the district 
   court's summary judgment is reversed. Judge Colloton, dissenting.