California Federal Court Says Employers Need Not Approve Multiple Leaves of Absence Where an Employee was Totally Disabled and Could Not Provide a Definite End Date to the Leave

Executive Summary: The Southern District Court of California, in Ruiz v. ParadigmWorks Group, Inc., held that an employer was not at fault for failing to grant an employee’s request for multiple medical leaves of absence where the employee was totally disabled and she could not provide a “finite end date to [her] total disability.”

In Ruiz, the employee was granted multiple leaves of absence and had been on leave for just over three months when she was terminated. When she was on leave, Ruiz was not able to perform any of the essential functions of her job. After she was terminated, Ruiz sued in federal court claiming disability discrimination in violation of state and federal law, as well as other state law claims.

Analyzing her disability discrimination claim, the court held that the “question presented . . . is not whether [an accommodation] imposes an undue hardship, but whether the accommodation requested is reasonable and thus required in the first place” quoting Raine v. City of Burbank, 135 Cal. App. 4th 1215, 1227 (2006). The court held, “Ruiz has the burden of proving that her requested extension of leave was a reasonable accommodation” and found that she had failed to meet this burden. The court explained that there was “no dispute that Ruiz was totally disabled and that no accommodation would have allowed her to perform her job …. Neither the ADA nor FEHA required [the employer] to extend Ruiz’s medical leave indefinitely until she was able to return to work.”

In light of this determination, the court granted the employer’s motion for summary judgment on the basis that the termination was a legitimate business decision.

Employers’ Bottom Line:

The court acknowledged that an individual who cannot perform the essential functions of her position may be qualified if she will be able to perform those functions at some definite point in the future, and if it would not pose an undue hardship on the employer to give the individual leave until that time arrives. In this case, however, there was no dispute that the employee was unable to perform the essential functions of her job when she requested the additional leave, nor did she provide the employer with a date by which she would be able to perform these functions.

Requests for leave must be evaluated on a case-by-case basis, but the court’s decision provides some guidance and a sigh of relief for employers who are faced with a similar situation where an employee who is totally disabled requests multiple leaves of absence with no “finite end date to his total disability.” If you have any questions regarding this decision, similar circumstances or other issues impacting California employers, please feel free to contact the author of this post, Astineh Arakelian, aarakelian@fordharrison.com, counsel in our Los Angeles office.

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