Severson v. Heartland Woodcraft, Inc.

From 2006-2013, Severson worked for Heartland, a fabricator of retail display fixtures. The work was physically demanding. In 2013, Severson took a 12-week medical leave under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, to deal with serious back pain. On the last day of his leave, he underwent back surgery, which required that he remain off of work for another two or three months. Severson asked Heartland to continue his medical leave, but he had exhausted his FMLA entitlement. The company terminated his employment but invited him to reapply when he was medically cleared to work. When Severson’s doctor cleared him to resume work, Severson did not reapply but sued under the Americans with Disabilities Act, 42 U.S.C. 12101. The district court awarded Heartland summary judgment. The Seventh Circuit affirmed. The ADA is an antidiscrimination statute, not a medical-leave entitlement. The Act forbids discrimination against a “qualified individual on the basis of disability.” A “qualified individual” with a disability is a person who, “with or without reasonable accommodation, can perform the essential functions of the employment position.” The term is limited to measures that will enable the employee to work. An employee who needs long-term medical leave cannot work and is not a “qualified individual.” View "Severson v. Heartland Woodcraft, Inc." on Justia Law