California’s Fair Employment and Housing Act (FEHA) requires employers to provide reasonable accommodations to help employees with disabilities perform their essential job duties, unless doing so would cause the employer an undue hardship. However, under California law, indefinite medical leave is generally not considered a reasonable accommodation. While employees are often entitled to take medical leave for a defined period, employers are not required to hold a position open indefinitely if there’s no clear timeline for the employee’s return to work.
Matt Ruggles has decades of employment litigation experience and has represented countless employees in California employment law cases, including those involving disability discrimination and wrongful termination.
A recent case involving an HVAC technician at the Getty Museum highlights the challenges employees face when requesting medical leave and accommodations. If you were fired after requesting accommodations for a disability or while on indefinite medical leave, this case provides critical lessons on your rights, responsibilities, and potential legal claims. Understanding why indefinite medical leave is not protected as a reasonable accommodation can help you better advocate for your rights and explore alternative accommodations that may better support your return to work.
Case Background: Manos v. The Getty Museum
The Workplace Injury and Indefinite Medical Leave
Imagine dedicating years to a physically demanding job, only to suffer a serious injury that puts your career on hold. That’s what happened to Manos, an HVAC technician at the Getty Museum, who faced a tough legal battle after his employer terminated him during an extended medical leave.
In 2011, Manos was hired as an HVAC technician at the Getty Museum, performing physically demanding tasks such as climbing, lifting, and working in confined spaces.
In June 2019, he fell from a ladder while servicing an ice machine, suffering a severe leg injury. He immediately requested medical leave, which the Getty approved. Over the next year, Manos submitted multiple requests to extend his leave, but each time his doctor provided an uncertain return date or marked his condition as indefinite.
Despite extending his leave for more than a year, in June 2020, the Getty terminated Manos’s employment, stating there was no foreseeable return date and that he had not requested any workplace accommodations beyond continued leave.
The Lawsuit: Key Legal Claims
Manos sued the Getty Museum, alleging:
- Retaliation for prior complaints about workplace misconduct,
- Failure to accommodate his disability,
- Failure to engage in the interactive process, and
- Wrongful termination in violation of public policy.
The Getty responded that it had provided leave well beyond what was legally required and had repeatedly asked Manos if he could return to work with accommodations—but he failed to respond.
Court’s Ruling: Why the Getty Won
The court ruled in favor of the Getty, granting summary judgment, meaning the case was dismissed before going to trial. Here’s why:
Fact #1: Indefinite Medical Leave Is Not a Reasonable Accommodation
- A leave of absence can be a reasonable accommodation under FEHA, but employers are not required to approve an indefinite leave.
- To qualify as a reasonable accommodation, medical leave must have a clear and specific return-to-work date.
- While an employer is not required to provide indefinite leave, extended leave may be considered reasonable if the employee provides a foreseeable return date. However, in this case, Manos’s doctor did not provide a clear timeframe, which weakened his claim.
- The Getty granted over a year of medical leave, but Manos’s requests for continued, indefinite leave were not considered reasonable.
- Employees should work with their doctors to provide a clear timeline for returning to work to ensure their leave is recognized as a legitimate accommodation under the law.
Fact #2: Employees Must Engage in the Interactive Process
- California law requires both employers and employees to engage in a good-faith discussion to explore reasonable accommodations.
- In early 2020, the Getty repeatedly asked Manos to identify possible job accommodations. While he did complete an Interactive Process Questionnaire, he indicated he was unable to work in any capacity and did not request any accommodations beyond continued leave.
- When Manos eventually filled out an Interactive Process Questionnaire, he stated:
- He was still unable to work in any capacity,
- He was not requesting any accommodations, and
- He was seeking continuous leave with no return date.
- Because he did not participate meaningfully in the process, his failure-to-accommodate claim failed.
Fact #3: No Evidence of Retaliation
- Manos had filed complaints against his supervisors two years before his termination.
- Retaliation claims require proof of a direct connection between the complaint and termination.
- A two-year gap made it difficult to prove retaliation, as courts often require a close timing connection between protected activity and termination. Without other supporting evidence of retaliation, the claim was dismissed.
Fact #4: Inconsistent Medical Records Hurt His Case
- After his termination, Manos signed legal documents stating he could not perform any job.
- His doctor’s statements were inconsistent—sometimes providing an estimated return date, other times marking it as “indefinite.”
- Courts rely on consistent medical documentation, and these contradictions weakened his case.
Key Takeaways for California Employees Regarding Disability Accommodation
- Provide a Clear Return Date if You Need Medical Leave
- Employers must provide reasonable leave, but indefinite leave is not required by law.
- Work with your doctor to set a clear return-to-work timeline.
- Engage in the Interactive Process
- If your employer asks about accommodations, you must respond.
- Suggest reasonable modifications that could allow you to work, such as:
- Modified job duties,
- Lighter physical tasks,
- Remote work options, or
- Schedule adjustments.
- Retaliation Claims Require Strong Evidence
- If you believe you were fired for reporting misconduct, you must prove a close time link.
- A two-year gap (as in this case) is too long to establish retaliation.
- Keep Your Medical Records and Statements Consistent
- If you claim you were able to work, but your doctor’s notes state otherwise, it can hurt your case.
- Ensure your medical records align with your legal claims.
- You Must Be Qualified for Alternative Positions
- If you argue that your employer should have reassigned you, you must prove you were qualified.
- In this case, Manos claimed he could have worked as a security officer, but the court found he lacked the necessary qualifications.
FREQUENTLY ASKED QUESTIONS ABOUT DISABILITY DISCRIMINATION
Can my employer fire me while I’m on indefinite medical leave?
An employer cannot terminate you simply because you are on medical leave. However, if you remain unable to work indefinitely and your employer can no longer hold your position open without undue hardship, they may legally terminate your employment. The key question is whether your employer has engaged in the required interactive process to explore reasonable accommodations before making that decision.
What is considered a “reasonable accommodation” under FEHA?
A reasonable accommodation is any workplace modification that enables an employee with a disability to perform their essential job functions. Common accommodations include modified work duties, assistive equipment, flexible scheduling, or temporary leave with a clear return date. However, an employer is not required to create a new position, eliminate essential job duties, or provide accommodations that cause significant hardship to the business.
How long can I be on medical leave before my employer can terminate me?
There is no exact time limit for medical leave under FEHA, but indefinite leave is not considered a reasonable accommodation. If your doctor cannot provide a specific return-to-work date and your employer determines that keeping your position open would create undue hardship, they may lawfully terminate your employment.
What should I do if I was fired after medical leave?
If you were terminated after taking medical leave, gather and preserve any emails, letters, or messages from your employer regarding your leave and any discussions about returning to work. If your employer failed to engage in the interactive process or ignored potential accommodations, consult an experienced employment attorney to review your case and determine if your rights were violated.
Can my employer refuse to engage in the interactive process?
No. California law requires employers to engage in good faith discussions to determine whether a reasonable accommodation can be made. If your employer ignores or refuses to explore accommodation options, they may be violating FEHA, and you may have grounds for a legal claim.
What evidence helps prove a wrongful termination case?
Strong evidence includes written communication with HR, such as emails or letters about your medical leave or accommodation requests. Medical records that confirm your ability to return to work can also support your claim, as well as statements from coworkers who witnessed employer actions. Additionally, reviewing your employer’s disability accommodation policies may reveal inconsistencies in how your case was handled.
Conclusion
This case highlights the importance of communication between employees and employers when dealing with disability accommodations. While California law provides strong protections, employees must be proactive in responding to employer requests, suggesting accommodations, and keeping their medical records consistent.
If you believe you have been wrongfully terminated due to a medical leave or disability, consult with an experienced employment attorney to evaluate your legal options.
Contact the Ruggles Law Firm at 916-758-8058 to Evaluate Your Potential Lawsuit
Matt Ruggles has a thorough understanding of California employment laws and decades of practical experience litigating employment law claims in California state and federal courts. Using all of his knowledge and experience, Matt and his team can quickly evaluate your potential claim and give you realistic advice on what you can expect if you sue your former employer.
Contact the Ruggles Law Firm at 916-758-8058 for a free, no obligation consultation.
Blog posts are not legal advice and are for information purposes only. Contact the Ruggles Law Firm for consideration of your individual circumstances.
