Giving an employee temporary light duty does not mean you have to create a permanent light duty position as a reasonable accommodation, at least according to a recent Sixth Circuit case. Here are the facts the Court considered in Meade v. AT&T Corporation:
Stephen Meade worked for AT&T as a facility technician, installing and maintaining telephone and internet equipment. After working for over 30 years, he suffered a job-related injury that resulted in a blood clot in his leg. Meade’s physician released him to return to work with temporary limitations that prevented him from working as a facility tech. When Meade returned to work, AT&T allowed him to perform light-duty tasks around the office. After AT&T learned that that his limitations were permanent, it offered Meade 40 weeks of termination pay, and provided options for Meade to apply for and obtain another position with AT&T. Following his termination, Meade did not apply for any positions; instead, he filed a lawsuit alleging that AT&T failed to reasonably accommodate his disability. Specifically, he claimed that AT&T should have allowed him to continue to perform light-duty work indefinitely.
Rejecting Meade’s claim, the court found that AT&T’s refusal essentially to create a permanent light-duty position did not violate the ADA. The district court granted summary judgment in favor of AT&T, and the Sixth Circuit affirmed.
The ADA requires an employer to provide reasonable accommodations, not any accommodation that an employee requests. The Sixth Circuit’s opinion underscores the fact that every possible accommodation is not necessarily reasonable. Here, the court found that requiring an employer to transform a temporary light-duty accommodation into a newly-created light-duty permanent position is unreasonable.
Employers in the Sixth Circuit can rest easy knowing that a short-term assignment of light duty tasks will not be construed as an agreement or obligation to create a permanent light duty position.