Raymond Severson v. Heartland Woodcraft, Inc.

Title I of the Americans with Disabilities Act (the “ADA”) requires employers to make “reasonable accommodations to the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or employee, unless [the employer] can demonstrate that the accommodation would impose an undue hardship * * * .” 42 U.S.C. § 12112(a), (b)(5)(A). The ADA defines a “qualified individual” as “an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8). The question presented is: Is there a per se rule that a finite leave of absence of more than one month cannot be a “reasonable accommodation” under 42 U.S.C. § 12112, or does the question of whether such a leave is a “reasonable accommodation” turn on the facts of the case?