7th Circuit Holds Long-Term Leave Is Not A Reasonable Accommodation Under The ADA

In a recent decision in Severson v. Heartland Woodcraft, Inc. (Sept. 20, 2017), the Seventh Circuit affirmed a district court's ruling that an employer did not violate the Americans With Disabilities Act (ADA) by failing to provide an employee with a long-term medical leave of absence. Indeed, the court found that "a long-term leave of absence cannot be a reasonable accommodation" under the ADA.

Plaintiff, a former employee of Heartland Woodcraft ("Heartland"), developed chronic back problems and became unable to work. After exhausting his Family and Medical Leave Act (FMLA) leave, he informed Heartland that he needed surgery, which would require him to be out of work for two to three additional months. Heartland responded that his employment would terminate at the end of his FMLA leave and he could reapply when he was able to return to work. After recovering from surgery and being cleared to return to work, rather than reapplying, the plaintiff sued, alleging that