Eleventh Circuit Rules That Employee Who Requested An Indefinite Leave of Absence Was Not a Qualified Individual With A Disability Under the ADA.
Wood v. Green, (11th Cir. March 13, 2003)
http://laws.findlaw.com/11th/0212971opn.htmlIn this case, the Eleventh Circuit decided that an individual who requested a leave of absence for an indefinite period of time was not a qualified individual with a disability under the ADA.
The plaintiff worked at a circuit court clerk’s office as a court coordinator. The plaintiff struggled with cluster headaches during his employment at the clerk’s office, but the defendant accommodated his need for time off when the cluster headaches arose. The defendant was very generous in granting the plaintiff time off when needed, (even one or two month long absences). The plaintiff’s health issues continued for many years. Finally, in 2000, the defendant terminated the plaintiff after he asked for a leave of absence for an indefinite period of time. The plaintiff subsequently sued and won a verdict in the District Court. The defendant then appealed the verdict to the Eleventh Circuit.
The Eleventh Circuit reversed the District Court and held that the plaintiff was not a qualified individual with a disability under the ADA because a request for an indefinite leave of absence is not a “reasonable accommodation” under the ADA. The Court reasoned that the requested accommodation would not have assisted the plaintiff in continuing to perform his essential job duties; rather it was a request for an accommodation that would have allowed him to work in the future at an unspecified time.