Employees Are Not Entitled to Multi-Month, Indefinite Medical Leaves of Absences
California employers can breathe a sigh of relief in light of a recent decision from the Southern District Court of California. In Ruiz v. ParadigmWorks Group, Inc., the Court held that an employer is not required to extend an employee’s “multi-month” medical leave of absence where the employee is temporarily totally disabled and cannot provide a definite end date to her leave.
In Ruiz, Plaintiff worked as a student outreach and admissions counselor and became unable to perform her essential job duties following a broken ankle from an accident at home. Pursuant to her doctor’s note, she was temporarily totally disabled from November 16 through November 20. On November 20, her doctor provided a second note stating she would be temporarily totally disabled through February 22. She was provided with unpaid leave through February 22, and she received disability benefits from the state.
On February 18, her doctor provided a third note stating that she would be temporarily totally disabled through April 1. Eleven days later, the Company fired her and invited her to apply for open positions after she recovered. Instead, six months later, when she was able to work again, Plaintiff sued the Company for disability discrimination under both federal and California law.
The employee argued that additional leave until April 1 would have been a reasonable accommodation. But since the Company had already given her two prior leave periods and she had been unable to return at the end of either of them, the court pointed out, and there was no evidence she would have been ready to return to work on April 1. Based on her inability to return to work at the end of the other two periods, the Company had no reason to believe she would be able to return to work on April 1. Indeed, that she continued to receive disability benefits from the state until September indicated that her disability did not end on April 1. Thus, the undisputed evidence was that the employee was totally disabled when the Company terminated her employment, and there was no evidence that a finite end date to her total disability was known when she was terminated.
The Court found in the Company’s favor in entirety. In doing so, the Court rejected Plaintiff’s argument that she was entitled to any further accommodation in the form of an approved leave of absence. The Court emphasized that there was “no dispute” that Plaintiff was totally disabled and that “no accommodation would have allowed her to perform her job.” As a result, the Court explained, the Company was not required to extend Plaintiff’s medical leave indefinitely. Thus, termination of her employment was an appropriate and legitimate business decision.
Importantly, the Court’s ruling applied in federal and state contexts, respectively under both the Americans with the Disabilities Amendments Act of 2008 (“ADAAA”) and the Fair Employment and Housing Act (“FEHA”).
What This Means for Employers:
When dealing with the “parade of doctor’s notes,” employers are often frustrated by the continuous extension of medical leaves. This case illustrates that when there have been multiple extensions for several months, and there is no clear and definite evidence that the employee will be able to return, the leave of absence takes on the characteristic of an indefinite leave. Contact Barsamian & Moody for assistance in determining whether a decision to terminate an employee while on medical leave is prudent in the circumstances.
The goal of this article is to provide employers with current labor and employment law information. The contents should neither be interpreted as, nor construed as legal advice or opinion. The reader should consult with Barsamian & Moody at (559) 248-2360, for individual responses to questions or concerns regarding any given situation.