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 totally disabled and cannot provide a definite end date to her leave. The Ruiz decision comes just seven days after the Ninth Circuit ruled in Markowitz v. United Parcel Services, Inc. that an employer may discharge an employee “if the employee is unable to perform his or her essential duties even with reasonable accommodation.”
In Ruiz, Plaintiff worked as a student outreach and admissions counselor and became unable to perform her essential job duties following an accident at home. As an accommodation, the Company granted her three consecutive leaves of absences that totaled fourteen weeks. When Plaintiff requested an additional six weeks of leave without any assurance of her return-to-work date, the Company terminated her employment and invited her to apply to open positions when she fully 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 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”). See Ruiz v. ParadigmWorks Group, Inc., 16:CV-2993-CAB-BGS (February 22, 2018).