## Facts

- Zenaida García-Ayala worked as a clerical employee in Lederle Parenterals, Inc.’s Validation Department from 1983 until termination in 1996.
- García had a long history of breast cancer treatment, including multiple surgeries and chemotherapy, resulting in substantial medical absences over several years.
- In June 1995, García began short-term disability leave due to cancer; Lederle reserved her position for one year under its practice.
- During García’s leave, Lederle used temporary employees to perform her duties; temporary coverage continued after her termination.
- As the one-year job-reservation period neared expiration (June 13, 1996), García requested an extension of leave until a medically projected return date around July 30, 1996.
- Lederle refused to extend the leave beyond its one-year job-reservation practice and terminated García on June 13, 1996.
- García sued under the Americans with Disabilities Act (ADA), seeking damages and other relief; the district court granted summary judgment for Lederle, holding the requested leave extension was not a reasonable accommodation and García was not “qualified.”
- The parties stipulated to the material facts, leaving the legal effect of those facts under the ADA as the sole dispute on appeal.

## Issues

1. Whether an employee who seeks a short, medically supported extension of leave beyond an employer’s fixed job-reservation period can be a “qualified individual with a disability” under the ADA.
2. Whether a finite additional leave request with an anticipated return date is a reasonable accommodation as a matter of law on stipulated facts.
3. Whether the employer carried its burden to show that granting the requested leave extension would impose an undue hardship.

## Decision

- The First Circuit reversed the summary judgment for Lederle.
- The court held García was a qualified individual with a disability because she could perform the job’s essential functions with the reasonable accommodation of a finite leave extension.
- The court held the requested extension to a near-term, specified return date was a reasonable accommodation on the stipulated record.
- The court held Lederle failed to produce evidence that the requested extension would cause undue hardship, relying instead on its internal one-year policy.
- The court directed entry of judgment for García on ADA liability and remanded for determination of damages and other appropriate relief.

## Legal Principles

- The ADA requires an individualized assessment of reasonable accommodation; internal leave or job-reservation policies do not control the statutory reasonableness inquiry.
- Leave from work, including medical leave, can be a reasonable accommodation when it is finite and reasonably definite, supported by medical information, and likely to enable return to essential job functions.
- Employers are not required to provide indefinite leave or tolerate unpredictable absenteeism, but cannot reject a time-limited request based solely on a blanket policy.
- After an employee shows a facially reasonable accommodation, the employer bears the burden to show undue hardship with concrete evidence of significant difficulty or expense.
- Evidence that the employer has effectively operated using temporary coverage may support feasibility and weaken claims that a short extension would be unworkable.

## Conclusion

The court held that a short, medically supported extension of leave beyond an employer’s fixed job-reservation period can be a reasonable ADA accommodation, and that an employer must prove undue hardship with evidence rather than relying on a categorical leave cutoff.


García-Ayala v. Lederle Parenterals, Inc., 212 F.3d 638 (1st Cir. 2000)