Angela Kendall v. Zoltek Corporation

── Angela Kendall v. Zoltek Corporation ── Court: Court of Appeals for the Eighth Circuit Date: May 18, 2026 Category: General United States Court of Appeals For the Eighth Circuit _______________________________ No. 25-1411 ___________________________ Angela Kendall Plaintiff - Appellant v. Zoltek Corporation Defendant - Appellee ____________ Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: January 13, 2026 Filed: May 18, 2026 ____________ Before SHEPHERD, KELLY, and STRAS, Circuit Judges. ____________ SHEPHERD, Circuit Judge. Angela Kendall sued her former employer—Zoltek Corporation (Zoltek)—alleging failure to accommodate and retaliation in violation of the Americans with Disabilities Act (ADA) and sex discrimination in violation of Title VII. The district court 1 granted summary judgment to Zoltek on all of Kendall’s 1 The Honorable John A. Ross, United States District Judge for the Eastern District of Missouri. claims. Kendall appeals the grant of summary judgment to Zoltek. Having jurisdiction under 28 U.S.C. § 1291, we affirm. I. Zoltek “produces essential products” as defined by a division of the U.S. Department of Homeland Security, and its “St. Peters facility supplies global products to wind turbine generators for renewable energy.” In 2018, Zoltek hired Angela Kendall to work as a production operator in its St. Peters facility. As a production operator, Kendall was expected to set up and operate equipment to process carbon fiber, restock materials, and pack, label, and document products, among other tasks. Kendall reported that operating the equipment to process carbon fiber required her to stand, bend over, squat, walk, and reach. Additionally, Zoltek’s advertised job description for a production operator indicated that interested persons had to meet certain physical requirements, including the ability to lift at least 25 pounds overhead, turn, bend, reach, pull, walk, and stand for up to 12 hours.2 In late April 2021, Kendall slipped while at work and went to the emergency room a few days later for continuing back pain. She was diagnosed with muscle spasms and potential sciatica. At a follow-up visit the next week, her doctor released her to return to work with no restrictions. In June 2021, however, Kendall provided Zoltek with a doctor’s note that stated: “Please allow Angela sitting time secondarily, during her work shifts due to her sciatica flare ups.” 3 Zoltek permitted this accommodation for several months. Despite this temporary accommodation, Zoltek viewed its standing requirement as particularly important for production 2 Although Zoltek hired Kendall as a production operator in 2018, the parties rely on Zoltek’s 2022 job description for the position. Because neither party argues otherwise, we assume that Zoltek’s 2018 job description did not materially differ from the 2022 version. 3 Although the parties do not explain what “sitting time secondarily” means, we presume it to mean sitting occasionally. -2- operators. Indeed, earlier in the year, Zoltek’s plant manager Dawn Pagano issued a “no sitting” reminder. Additionally, after providing Kendall an accommodation, Zoltek management informed the other production operators that “[n]obody’s supposed to be sitting down but Angela.” Although Kendall contends that fellow production operator Tyrone Brooks was allowed to sit during his shift, Zolt