A plaintiff with chemical or other sensitivities alleging disability discrimination is not unusual. The typical claim is that such a plaintiff, despite such sensitivities, is a qualified individual with a disability and the employer failed to accommodate those sensitivities. The pro se plaintiff in an Eleventh Circuit case making that claim, a nurse in a VA hospital, had more than the usual number of sensitivities. According to the Court, the plaintiff “had suffered allergic reactions or experienced sensitivity to floor sealant, floor stripper, cleaning products, chemical solvents, ammonia, rubbing alcohol, sprays, molds, dust, perfumes, scents and odors, fumes of any kind, latex, insect bites, changes in temperature or weather, volatile compounds, asbestos, and industrial equipment.” Her doctor said she “must NOT be within less than one foot” of certain chemicals or solvents. The Court held that because her employer “could not guarantee that she would not come near the hundreds of chemicals it commonly used at its facility,” the plaintiff could not perform the essential functions of her position, with or without accommodation, and, for that reason, was not a qualified individual under the Rehabilitation Act. Dickerson v. Secretary, Dep’t of Veterans Affairs Agency (11th Cir. September 7, 2012).