## Facts

- Raymond Severson worked for Heartland Woodcraft, Inc. in a physically demanding job from 2006 to 2013.
- Severson had serious back problems causing flareups that could prevent walking, bending, lifting, sitting, standing, and moving.
- In June 2013, he began a 12-week medical leave under the FMLA for severe back pain.
- On the last day of his FMLA leave, Severson underwent back surgery and was unable to work for an additional two to three months.
- Severson requested an additional two to three months of leave beyond the FMLA period as an accommodation.
- Heartland denied the extended-leave request, terminated his employment, and invited him to reapply when medically cleared.
- About three months later, Severson’s doctor lifted work restrictions; Severson did not reapply and instead sued, alleging failure to accommodate under the ADA.

## Issues

1. Whether a multi-month leave of absence after FMLA leave expires can be a “reasonable accommodation” under Title I of the ADA.
2. Whether an employee who cannot work for the leave period is a “qualified individual” who can perform the job’s essential functions with or without reasonable accommodation.

## Decision

- The Seventh Circuit affirmed summary judgment for Heartland.
- The court held that a multi-month leave of absence is beyond the scope of a reasonable accommodation under the ADA.
- Because Severson could not perform the essential functions of his job during the requested extended leave, he was not a “qualified individual” at the time of termination.
- The court rejected the request (supported by the EEOC) to limit or reconsider its prior precedent treating long-term leave as outside the ADA’s accommodation requirement.

## Legal Principles

- The ADA’s reasonable-accommodation duty is limited to measures that enable an employee to perform the essential functions of the job.
- An employee who needs long-term medical leave cannot work and therefore is not a “qualified individual” under the ADA during that period.
- The ADA is an antidiscrimination statute and does not create a general medical-leave entitlement distinct from the FMLA’s protected leave framework.
- Short or intermittent leave may qualify as an accommodation in some circumstances, but a multi-month absence that removes the employee from working does not.

## Conclusion

The court concluded that an employer does not violate the ADA by refusing to grant a multi-month leave of absence after FMLA leave is exhausted, because such leave does not enable performance of essential job functions and the employee is not a qualified individual during the requested absence.


Severson v. Heartland Woodcraft, Inc., 872 F.3d 476 (7th Cir. 2017)