Leave and Reassignment under the ADA

March 2000

The American with Disabilities Act's reasonable accommodation mandate imposes potentially significant obligations on employers, particularly with regard to the obligation to provide additional unpaid leave and reassignment to a different position. Employers should carefully consider adopting a proactive disability management program to ensure appropriate leave, reassignment, and other accommodation of disabled employees.

by Christopher G. Bell and Paul J. Siegel
Jackson, Lewis, Schnitzler & Krupman

The American with Disabilities Act's (ADA's) reasonable accommodation mandate imposes potentially significant obligations on employers. This is particularly true with regard to the obligation to provide additional unpaid leave and reassignment to a different position of a disabled employee unable to perform in his or her original position even with accommodation.

As interpreted by both the Equal Employment Opportunity Commission (EEOC) and many courts, an employer now must consider providing significant additional leave after an employee has exhausted the 12-week leave entitlement allowed under the Family Medical Leave Act (FMLA). In addition, an employer may have an affirmative duty to search for a suitable vacancy for a disabled current employee and place such employee in the vacant position on a noncompetitive basis.

This article summarizes recent case law on these expanding areas of reasonable accommodation

Leave

Most courts and the EEOC agree that unpaid leave is a form of reasonable accommodation when it is necessitated by an employee's disability. Unpaid leave may be appropriate when a disabled employee needs time off to get treatment or recover from a disability-related illness, or take some type of other action needed because of the disability, such as learning Braille or training a guide dog. Unless an employer can show the leave would create an undue hardship, most courts will view it as a reasonable accommodation.

Significant leave is not generally required except where the employer's own policies provide otherwise. Likewise, most courts have held indefinite leave is not a reasonable accommodation.

While the EEOC has constantly taken the position that leave is always an accommodation, absent undue hardship, a number of courts have held leave is an appropriate accommodation only in certain circumstances-the need for leave must at least be related to the disability. See Bailey v Amsted Industries, Inc., 172 F3d 1041 (8th Cir 1999) (where employee's absenteeism not related to disability, employee not entitled to leave as a reasonable accommodation under the ADA and did not qualify under the FMLA).

Though leave itself may be a reasonable accommodation, the amount of leave that is reasonable is fairly fact-specific depending on the position the employee holds, the needs of the employer, and the amount of time requested. For example, in Haschmann v Time Warner Entertainment Co., 151 F3d 591 (7th Cir 1998), the employer denied a leave request from an employee who had flare-ups of lupus and instead terminated the employee for poor performance. The court found the employer failed to show that leave would cause undue hardship or that leave was an unreasonable request.

In contrast, the court in Walton v Mental Health Assn. of Southeastern Pennsylvania, 168 F3d 661 (3rd Cir 1999), found a 2½-month leave was excessive and caused undue hardship where employee's presence was essential at the time due to fear the program she headed would fail for lack of funding and leadership. Thus, where the employer can show the leave would create undue hardship, it will not be liable for failing to accommodate.

However, any examination of leave should take into account the employer's obligations under the FMLA. For example, in Cehr v Northeast Ohio Alzheimer's Research Center, 155 F3d 775, 783 (6th Cir 1998), the court noted that, by enactment of the FMLA, Congress has determined:

uninterrupted attendance in the face of a family medical emergency is not a necessary job requirement and does not unduly burden employers.

It could fairly be said that leave under the FMLA is now a floor on the amount of absence an employer must tolerate for an employee's disability under the ADA. However, the FMLA does not create a ceiling on leave under the ADA.

Must the Employer Hold the Employee's Job Open?

The EEOC takes the position that the employer must hold the employee's job open as a reasonable accommodation, unless doing so would create an undue hardship. According to the agency's view, leave would hardly be an accommodation if the employee could not come back to his former position.

However, if keeping the position open is an undue hardship, the EEOC states the employer must then consider whether it has a vacant, equivalent position for which the employee is qualified and to which he may be reassigned. The employee is then still accommodated, and the employer's needs are met while the employee is out on leave.

Courts that have dealt with the issue have insinuated that keeping the employee's job open while she is out on an leave to deal with a disability is reasonable, absent undue hardship. In Monette v Electronic Data Systems, 90 F3d 1173 (6th Cir 1996), the court intimated that if the employee expressed a desire to return to work through his words and actions, the employer may have a duty to keep the employee's job open. See also Schmidt v Safeway, 864 F Supp 991 (D Ore 1994), and Corbett v National Products Co., 4 AD Cas 987 (ED Pa 1995).

Definite versus Indefinite Time Periods

Most courts have stated that significant, indefinite, and unpredictable leaves are not reasonable accommodations under the ADA. For example, in Gantt v Wilson Sporting Goods Co., 143 F3d 1042 (6th Cir 1998), the employee was terminated for failure to return to employment after a 1-year leave of absence. The court ruled the employee was not discriminated against because reasonable accommodation does not require to employer to wait indefinitely for an employee's medical condition to be corrected.

Similarly, in Monette v Electronic Data Systems, supra, the court ruled the employer could assume the employee was asking for indefinite leave not required under the ADA where the employee never expressed a desire to return to work and applied for permanent disability benefits.

In Walsh v United Parcel Service, 2000 WL 10605 (6th Cir January 6, 2000), the employee requested additional leave of 1 to 3 years after his employer already allowed him a 1½-year leave. The Sixth Circuit stated that when an accommodation does not have a reasonable prospect of allowing an individual to return to work in the identifiable future, "it is objectively not an accommodation that the employer should be required to provide." The court affirmed summary judgment for the employer, holding that:

when ... an employer has already provided a substantial leave, an additional leave period of a significant duration, with no clear prospects for recovery, is an objectively unreasonable accommodation.

The Fourth, Fifth, Seventh, Ninth, Tenth, and Eleventh Circuits have agreed. See, for example, the following cases.

However, where an employer's policies regarding leave are generous, some courts have ruled that leave up to and including a year is not unreasonable. See the following.

Further, at least one court has determined that indefinite leave is not per se unreasonable under the ADA. See Norris v Allied Sysco Food Services, Inc., 948 F Supp 1418 (ND Cal 1996).

The EEOC's position on this issue, as well as on other accommodations, is that the reasonableness should be determined on a case-by-case basis.

Unpredictable Attendance

Most courts agree that reliable attendance is required to perform most jobs and, therefore, an employer need not provide leave for employees taking unpredictable absences. For example, in Waggoner v Olin Corp., 169 F3d 481, 484 (7th Cir 1999), the court stated as follows.

[T]he ADA does not protect persons who have erratic, unexplained absences, even when those absences are a result of a disability. The fact is that in most cases, attendance at the job site is a basic requirement of most jobs.

Similarly, in Nowak v St. Rita High School, supra, the court found an employee who was unable or unwilling to perform an essential function of the job-regular attendance-for a period of 18 months was not a "qualified individual with a disability." Likewise, in Jackson v Veterans Admin., 22 F3d 277, 280 (11th Cir 1994), the court stated that employers under the Rehabilitation Act are not required to accommodate periodic, unanticipated absences of a probationary employee, and the employee was not qualified when he missed 6 days in 3 months.

In Carr v Reno, 23 F3d 525 (DC Cir 1994), the court also found the employee not qualified when she could not appear for work regularly. In Deal v Candid Color Systems, 1998 U.S. App LEXIS 15018 (10th Cir 1998) (unpublished), the court found the employer did not have to reasonably accommodate an employee with leave where the employee could work so sporadically and infrequently that a "second employee would be required to perform her duties."

Likewise, in Nesser v Trans World Airlines, Inc., 160 F3d 442 (8th Cir 1998), where the employer considered attendance to be an essential function of the employee's position, and the employee could not show that reasonable accommodation was possible with respect to his attendance, the employer was entitled to summary judgment. Finally, where an employer maintains an attendance policy, an employee who is terminated because of excessive absenteeism is not a "qualified individual with a disability." See Greer v Emerson Elec. Co., 185 F3d 917 (8th Cir 1999).

See also the following cases.

Finally, in Kennedy v Applause, Inc., 3 AD Cas 1734, 1737 (CD Cal 1994), affirmed on other grounds, 90 F3d 1477 (9th Cir 1996), the employee's own physician indicated she could not maintain regular attendance. The court therefore found that the employee was not qualified and the employer need not provide the employee with an open-ended schedule.

Other courts leave the issue for the jury to decide whether or the degree to which attendance is an essential part of the job in question. The court in Haschmann v Time Warner Entertainment Co., supra, ruled the question is one of fact for the jury. The court said as follows.

We do not dispute that a business needs its employees to be in regular attendance to function smoothly; the absence of employees is disruptive to any work environment. However, it is not the absence itself but rather the excessive frequency of an employee's absences in relation to that employee's job responsibilities that may lead to a finding that an employee is unable to perform the duties of his job. Consideration of the degree of excessiveness is a factual issue well suited to a jury determination.

The EEOC does not see attendance as an essential function of any job under the ADA, because it is not a job duty. This position has found support in at least a couple decisions where the focus is on the amount of attendance missed and the belief that uninterrupted attendance is never an essential function of any position.

For example, in Cehrs v Northeast Ohio Alzheimer's Research Center, supra, the court ruled no presumption should exist that uninterrupted attendance is an essential job requirement (particularly in light of FMLA), and medical leave of absence can be a reasonable accommodation, especially where company routinely granted medical leave of absence to employees.

Similarly, in Dutton v Johnson County Bd. of County Commissioners, 859 F Supp 498 (D Kan 1994), the court found that failure to permit an employee to use accrued leave violated ADA. The court reasoned that if the employer were willing to accept an employee's use of unscheduled leave by allowing him to use his vacation time, the employee could perform the essential functions of his job.

No-Fault Attendance Policies

Employers who have a "no-fault" attendance policy where all employees get a certain amount of leave, after which they are terminated, may still employ the policy as it is, not in itself an ADA violation. In Gantt v Wilson Sporting Goods Co., supra, the court ruled that an employer's policy of terminating employees who have been on leave for over a year did not violate the ADA. Similarly, a uniformly applied attendance policy requiring not more than 3 percent absenteeism has been found not to violate the ADA in Price v S-B Power Tool, supra.

More recently, in Stanback v Best Diversified Products, Inc., 180 F3d 903 (8th Cir 1999), the Eighth Circuit ruled that an employer's attendance policy of termination after 10 days missed in a year was not in violation of the ADA when nondiscriminatorily applied. However, in its Guidance, the EEOC states an employer may not apply a "no-fault" leave policy to employees who need leave beyond the stated time because of their disability. The policy must be modified to provide the employee with additional leave unless the employer can show another effective accommodation would allow the employee to perform the essential functions of the position or granting additional leave would cause undue hardship.

The EEOC also states an employer may not discipline an employee for work missed during a leave that is taken as a reasonable accommodation. This means an employee's nonperformance during leave cannot be used against him when the employer makes performance-based termination decisions. Examples given by the EEOC include application of an employer policy that terminates poor performing employees when the employee's poor performance was due to a leave for disability reasons and considering a disabled employee for using leave for his or her disability when leave is a necessary accommodation.

Consideration of Employer's Leave Policies

Some courts consider the employer's leave policies in determining whether or not the requested leave would pose an undue hardship. For example, the First Circuit reviewed an employer's leave policies in Criado v IBM Corp., supra, and stated the employer could not claim undue hardship where its manager testified the company's 52-week disability leave policy":

did not financially burden [the employer] because it recognized that it was always more profitable to allow an employee time to recover than to hire and train a new employee.

Similarly, in Rascon v U S West Communications, Inc., supra, the court found a 4-month leave of absence to attend inpatient treatment program for post traumatic stress disorder was a reasonable accommodation where employee requested leave of a specific duration, kept his employer appraised of his status, and the employer had generous leave policies available to the employee which the employer did not communicate when leave was requested.

Additionally, in Cehrs v Northeast Ohio Alzheimer's Research Center, supra, the court considered the amount of time an employer allows under a leave policy may be proof that leave of a lesser amount would not cause undue hardship. Finally, in Ralph v Lucent Technologies, Inc., supra, the court found that where an employer has a policy allowing employees 52 weeks of paid leave, an additional 4 weeks of part-time work was a reasonable accommodation.

Modified or Part-Time Schedules

An employer may have to modify an employee's work schedule as a reasonable accommodation. This includes modifying when things get done, the length and number of breaks, and the employee's starting or departure times. The key in these cases is whether the change is needed because of the disability, that is, whether it will assist the employee in performing the essential functions of the job, and whether the requested accommodation would cause an undue hardship to the employer.

Where the requested accommodation is not because of the disability, courts will not hold employers liable for failing to provide it. For example, in Turco v Hoechest Celanese Chemical Groups, Inc., 101 F3d 1090 (5th Cir 1996) (per curiam), the Fifth Circuit rejected an employee's claim that his employer unreasonably failed to accommodate him by failing to provide a fixed daytime shift when the employer had only rotating shifts for those in the position the employee held. The court found no violation because the requested accommodation would not eliminate problems the employee had with concentration, and it would require other employees to work harder or longer.

Similarly, in Gaines v Runyon, 107 F3d 1171 (6th Cir 1997), the court found an epileptic's request for a schedule change was not necessary for his disability because his medical records showed only that he needed a straight shift, which he already had.

The duty to accommodate an employee's disability by altering normal start and ending times is not absolute. In Guice-Mills v Derwinski, 967 F2d 794 (2nd Cir 1992), the employer required the head nurse to report to work at 8:00 a.m. At that time of day, the head nurse was in charge of the facility and was the only manager and non-union person on duty. Since attendance was an essential function of the position, the court found the nurse was not a qualified individual with a disability.

Similarly in Buckles v First Data Resources, Inc., 176 F3d 1098, 1101 (8th Cir 1999), the employer allowed the employee to leave his work area when he thought he would be exposed to an irritant. Instead of just leaving the work area, the employee left the building and went home. The court ruled that the "unfettered ability to leave work at any time is certainly not a reasonable accommodation."

Other than FMLA-reduced leave, courts generally do not feel the ADA provides entitlement to part-time work. The EEOC states modification of a job to a part-time position may be a reasonable accommodation, but its statement conflicts with other well-founded principles.

First, employers need not create new positions for disabled employees. Ostensibly, changing a position from full- to part-time would be creating a new position.

Second, full-time employment may be an essential function of the position. Thus, the employee would not be a qualified individual with a disability if she could not perform this function.

Third, the ADA does not require that employers transfer essential functions of a position to other coworkers or hire someone to assist the disabled employee. If the job requires a full-time person, the accommodation may not be reasonable because the employer is forced to hire someone to assist or transfer the disabled employee's duties to someone else when the employee is not there.

Most courts considering the issue suggest that part-time work is not a reasonable accommodation. For example, in Terrell v US Air, 132 F3d 621 (11th Cir 1998), the court held that the employer was not obligated to create a part-time position for a reservations agent with carpal tunnel syndrome. Similarly in Burch v Coca-Cola, 119 F3d 305 (5th Cir 1997), the court found the employer was not required to create a part-time position if the employee's position required full-time duties.

In Soto-Ocasio v Federal Exp. Corp., 150 F3d 14 (1st Cir 1998), the court found the employee's job required 6 to 9 hours of data entry every day. In that case, working part-time was not a reasonable accommodation because it would reallocate the employee's job duties and create more work for other employees, neither of which is required by the ADA.

Finally, if the employee's requested accommodation would remove the essential functions of her position, it need not be provided because the employee is not a "qualified individual with a disability." In Miller v Illinois Dept. Of Corrections, 107 F3d 483 (7th Cir 1997), a guard requested that her job be restructured so she would only rotate between the two positions she could perform. Because the essential function of the guard position required rotating through various duty positions and being able to assist other guards, the court found she was not a qualified individual with a disability.

Reassignment

The ADA specifically lists "reassignment to a vacant position" as a form of reasonable accommodation available to qualified individuals with disabilities [42 USC § 12111(9)(B) (1994)]. Reassignment must be provided to employees who can no longer perform the essential functions of their current position, with or without accommodation, because of their disability.

The EEOC states reassignment is a reasonable accommodation of "last resort" and is only required after determining that no effective accommodations will enable the employee to perform the essential functions of his or her current position or that all other reasonable accommodations would pose an undue hardship. Although controversy exists about the breadth of an employer's duty to reassign, some points are clear.

  1. Employees are only entitled to reassignment to vacant positions.
  2. The employee must be qualified for the position they seek, meaning they can perform the essential functions of the position they seek with or without accommodation.
  3. The employer does not have any duty to promote the employee to a vacant position.
  4. Employers are not required to bump other employees from positions to accommodate the disabled employee.
  5. Only current employees, not applicants, are entitled to reassignment.

Employer's Duty To Help Employee Find a Position

The EEOC states employers have a duty to assist qualified individuals with disabilities in locating vacant positions within their organization. At least the Third, Seventh, and Tenth Circuits have agreed.

In Hendricks-Robinson v Excel Corp., 154 F3d 685, 695-96, 697-98 (7th Cir 1998), the employer had a policy of placing injured workers in light-duty positions until they reached MMI. At that point, the employee either had to return to his former job, if he could, or obtain a new position. If no position was available, the employee was placed on medical leave for a year, during which the employee was to call in weekly to inquire about open positions for which they may be qualified.

The employer automatically bid the injured worker for production jobs, but did not disclose nonproduction jobs unless the employee specifically asked. Further, the jobs were only posted at the plant for a period of 2 days, where the injured employee had no access. The court ruled Excel's policy violated the ADA because it did not identify the full range of alternative positions for which the individual may qualify.

Similarly, in Mengine v Runyon, 114 F3d 415, 420 (3rd Cir 1997), the court ruled an employer has a duty to make reasonable efforts to assist an employee in identifying a vacancy because an employee will not have the ability or resources to identify a vacant position absent participation by the employer. See also Woodman v Runyon, 132 F3d 1330, 1334 (10th Cir 1997) (under Rehabilitation Act, federal employers are far better placed than employees to investigate in good faith the availability of vacant positions).

The Ninth Circuit has also intimated it will adopt this view. In McAlindin v County of San Diego, 1999 WL 717728 (9th Cir September 16, 1999), the Ninth Circuit reversed summary judgment on the district court's finding that the employer was not required to assist the employee in arranging a transfer. The court stated the issue is not whether the employer normally assists employees in arranging transfers but "whether a particular accommodation would be burdensome to the employer."

Further, the court held, there is a presumption under the ADA that an accommodation is required absent a showing of undue hardship. Therefore, the burden is on the employer to show the requested accommodation is unduly burdensome and poses an undue hardship.

In Wellington v The Lyon County School Dist., ___ F3d ___, 1999 WL 635742 (9th Cir August 23, 1999), the Ninth Circuit ruled a fact question existed precluding summary judgment as to whether the employer voluntarily created a position for an alleged disabled employee before it decided to terminate his employment instead.

The Extent of the Search

Employers have successfully argued their obligation to reassign an employee is limited to a specific department or location. In Riley v Weyerhaeuser Paper Co., 898 F Supp 324 (WD NC 1995), affirmed, 77 F3d 470 (4th Cir 1996), the court held that unless an employer regularly transferred employees to another company facility, it need not transfer a disabled employee to that facility.

Similarly, in Emrick v Libbey-Owens-Ford Co., 875 F Supp 393 (ED Tex 1995), the court held an employer need only transfer a disabled employee to another facility if it is the employer's regular practice to do so. In other words, policies affecting an employee's ability to transfer must be applied uniformly to disabled and nondisabled employees, and nondisabled employees will not be treated more favorably.

The EEOC disagrees with this analysis. In its Guidance, the EEOC states that because the ADA does not contain language limiting the duty to reassign to a particular area, and the ADA requires an employer to modify workplace policies as a reasonable accommodation, any policy limiting transfers "cannot be a per se bar to reassigning someone outside his/her department or facility."

Further, the Guidance states that the ADA:

requires employers to provide reasonable accommodations, including reassignment, regardless of whether such accommodations are routinely granted to nondisabled employees.

Some courts agree with the EEOC. In Buckingham v U.S. Postal Service, 998 F2d 735 (9th Cir 1993), the employee sought a transfer from Mississippi to California for better medical treatment of human immunodeficiency virus (HIV). The court ruled that because the government had an affirmative duty to make a reasonable accommodation under the Rehabilitation Act and is obligated not to interfere with an handicapped employee's efforts to pursue a normal life, the employer must accommodate the employee unless doing so would cause undue hardship.

In Gile v United Airlines, Inc., 95 F3d 492 (7th Cir 1996), the court rejected the employer's argument that it was only obligated to consider reassigning the plaintiff to positions inside her department for which she previously requested transfer.

Preferential Treatment for Disabled Employees

The EEOC states an employee with a disability is given preference over others competing for the same position when reassignment is the only accommodation available. Some courts agree.

In Smith v Midland Brake, Inc., ___ F3d ___, 1999 WL 3874978 (10th Cir 1999) (en banc), the Tenth Circuit examined this issue and agreed with the EEOC. The court stated that the ADA gives disabled employees preferential treatment in reassignment over other candidates for the position because, reading the statute as a whole, reassignment is an accommodation, which is more than an opportunity to compete with others for the same position.

Similarly, the court in Aka v Washington Hosp. Ctr., 156 F3d 1284, 1304-05 (DC Cir 1998), reasoned that:

[a]n employee who is allowed to compete for jobs precisely like any other applicant has not been "reassigned."

The court in Wood v County of Alameda, 5 AD Cas 173, 184 (ND Cal 1995), also stated an employee who can no longer perform the essential functions of her old job because of a disability is entitled to reassignment to a vacant position, not just an opportunity to compete.

The Fifth Circuit ruled opposite in Daugherty v City of El Paso, 56 F3d 695 (5th Cir 1995), certiorari denied, 516 U.S. 1122, 116 S Ct 1263, 134 L Ed 2d 211 (1996). There, the court stated as follows.

[W]e do not read the ADA as requiring affirmative action in favor of individuals with disabilities, in the sense of requiring that disabled persons be given priority in hiring or reassignment over those who are not disabled.

Employee Qualification and Reassignment Eligibility

Some courts have ruled that the employee must be qualified for the position they currently hold to be entitled to reassignment to another position. For example, in Schmidt v Methodist Hosp. of Indiana, Inc., 89 F3d 342 (7th Cir 1996), the court held a nurse with hearing loss who could not perform the essential functions of position for which he was hired was not a qualified individual under the ADA and thus not entitled to reassignment.

The EEOC and most courts disagree and hold the individual must only be qualified for the position to which they seek to be reassigned. See, for example, the following cases.

Reassignment to Equivalent or Lower Level Position

An employee is not entitled to be reassigned to a position that would constitute a promotion, but rather only to a vacant position equivalent to the position they currently hold and for which they are qualified. The Second Circuit has found that where a position exists which is equivalent in pay and benefits, the employer does not discharge its duty to reasonably accommodate under the ADA by offering the employee positions that are inferior in pay and benefits. See Norville v Staten Island Univ. Hosp., 1999 WL 996945 (2nd Cir November 2, 1999).

If no equivalent position is available, the employer must reassign the employee to a vacant lower level position if available. For example, in Fjellestad v Pizza Hut of America, Inc., ___ F3d ___, 1999 WL 642958 (8th Cir August 25, 1999), the unit manager of a restaurant could no longer perform the essential duties of her position due to restrictions on the amount of hours she could work. When her subordinate, the swing shift manager, was promoted to the disabled employee's position, the unit manager requested the demotion to swing shift manager, which she stated she could perform. The court ruled the employee may be entitled to reassignment to her subordinate's position if it was within her restrictions.

See also Cassidy v Detroit Edison Co., supra (reassignment to a lower job grade position appropriate if employee cannot be accommodated in current or comparable position).

Conclusion

The ADA is being construed to impose significant obligations on an employer to provide leave and reassignment in order to avoid termination of injured or ill employees with a disability. Employers should carefully consider adopting a proactive disability management program to ensure appropriate leave, reassignment, and other accommodation of disabled employees.

Opinions expressed in Expert Commentary articles are those of the author and are not necessarily held by the author's employer or IRMI. Expert Commentary articles and other IRMI Online content do not purport to provide legal, accounting, or other professional advice or opinion. If such advice is needed, consult with your attorney, accountant, or other qualified adviser.

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