Seventh Circuit Ruling on Leaves of Absence as an ADA Reasonable Accommodation
On September 20, 2017, the federal Seventh Circuit Court of Appeals, interpreting the “reasonable accommodation” requirement of the Americans with Disabilities Act, held that the Act does not require employers to provide employees with a long-term leave of absence that exceeds the leave time granted to employees by the Family Medical Leave Act and the employer’s leave policies. Raymond Severson v. Heartland Woodcraft, Inc., No. 15-3754. In this case, a three month extended leave was considered a long-term leave.
The Seventh Circuit explained that a reasonable accommodation is intended to allow an employee with a disability to perform the essential functions of his or her position, meaning that the purpose of a reasonable accommodation is to give an employee ‘the means to work,” and is not meant to excuse the employee from work. The Court’s opinion also provided guidance on two other frequently requested forms of a reasonable accommodation: reassignment to a vacant position or a light-duty position.
Click here for a more detailed summary of the Court’s decision.