Susan Qashu v. Marco Rubio

── Susan Qashu v. Marco Rubio ── Court: Court of Appeals for the D.C. Circuit Date: April 10, 2026 Category: General United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT Argued September 9, 2025 Decided April 10, 2026 No. 24-5201 SUSAN QASHU, PH.D., ALSO KNOWN AS PAMALA L., APPELLANT v. MARCO RUBIO, APPELLEE Appeal from the United States District Court for the District of Columbia (No. 1:22-cv-01077) Natasha R. Khan argued the cause for appellant. On the briefs were Joanna Wasik, Madeleine Gates, Regina Wang, Brian Wolfman, and Jonathan Corn, and Morgan F. Flitt, Matt Grabianski, Sara Brizio, Shreya Sarin, and Grace Seifert, Student Counsels. Ryan C. Downer entered an appearance. Johnny H. Walker, Assistant U.S. Attorney, argued the cause for appellee. With him on the brief was Jane M. Lyons, Assistant U.S. Attorney. Lshauntee J. Robertson, Assistant U.S. Attorney, entered an appearance.  2 Before: SRINIVASAN, Chief Judge, WALKER, Circuit Judge, and GINSBURG, Senior Circuit Judge. Opinion for the Court filed by Circuit Judge WALKER. WALKER, Circuit Judge: Susan Qashu sued the Department of State for a failure to accommodate her disability, discrimination based on that disability, and retaliation for her disability-related complaints. The district court granted summary judgment to the State Department. We affirm. I. Background The American Association for the Advancement of Science promotes “science, engineering, and innovation throughout the world for the benefit of all.” Mission and History, American Association For The Advancement Of Science, https://perma.cc/4FTE-A9VU. Among its many programs is a fellowship at the State Department. The fellowship lasts one year, with the possibility of a second year if mutually desired by AAAS, the State Department, and the fellow. The State Department hired Susan Qashu as an AAAS fellow to begin in February 2016. Because Qashu is visually impaired, the State Department’s Disability and Reasonable Accommodation Division provided her with several accommodations. The accommodations included software to help Qashu read her computer screen, and noise-cancelling headphones to help her hear the software read to her.  3 Qashu’s year did not go well. She says the State Department gave her screen-reading software that did not work well enough and then failed to promptly provide her with people to read aloud from her computer screen. The State Department also placed her in an office that was not sufficiently quiet, and the noise interfered with the use of her screen-reading software. In addition, she claims her supervisor “berated” her and “screamed” at her. JA 245. In June 2016, Qashu received a letter from AAAS offering to renew her fellowship for another year, beginning next February. AAAS asked her to sign and return the renewal paperwork by June 10. When Qashu proposed delaying the return of the renewal paperwork until June 16, AAAS agreed. But after proposing several changes to the renewal paperwork over the next several weeks, Qashu did not return it. The State Department and AAAS eventually decided to rescind her renewal offer. A new letter from AAAS, dated July 19, noted that the deadline to submit renewal paperwork had passed “more than a month ago” and that discussions with Qashu and the State Department showed their interests were “not aligned to result in a mutually beneficial renewal year.” JA 231. In August 2016, halfway through her fellowship year, Qashu filed a formal complaint with the State Department’s Office of Civil Rights. In it, she alleged discrimination based on her disability and reprisal. Her evidence included an email documenting demeaning comments by her supervisor, the denial of professional opportunities, and the rescission