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The Employer Handbook Blog
The ADA Has Boundaries. Here’s What They Look Like in Court.
Some jobs just require heavy lifting—literally. And courts aren’t about to tell employers to rewrite essential duties just because someone asks for an exception.
TL;DR: An employee recovering from a disability asked to return to his old job, but he couldn’t meet the essential physical demands. The employer denied the request, offered extensive leave, and explored alternatives. The Ninth Circuit affirmed summary judgment: the ADA doesn’t require eliminating core job functions or creating new roles out of thin air.
⚙️ The Role That Couldn’t Be Rebuilt
The employee worked in a physically demanding maintenance role—performing mechanical repairs on industrial equipment that involved lifting, twisting, kneeling, crawling, and carrying heavy loads.
After taking medical leave, the employee’s doctor restricted him from lifting more than 10 pounds and barred bending, squatting, and twisting. Despite these restrictions, he asked to return to the same job.
The company declined. According to the job description—and confirmed by employee testimony—repair duties were essential and expected of everyone in the position, even if some tasks varied day-to-day.
⚖️ The Legal Standard: What the ADA Requires
To bring a valid ADA claim, an employee must be a “qualified individual with a disability.” That means:
- They have a disability as defined by law, and
- They can perform the essential functions of the job, with or without reasonable accommodation.
Essential functions are the core duties of a role. Reasonable accommodations might include job restructuring, modified equipment, reassignment, or leave—but employers don’t have to remove essential duties, create new jobs, or offer indefinite leave.
🧑⚖️ The Court Weighed the Options—and the Evidence
The Ninth Circuit wasn’t persuaded that the employee could still do the job. Here’s why his ADA and state law claims failed:
- Not “qualified” under the ADA.
The job required lifting, bending, twisting, and making repairs. His doctor said he couldn’t do any of that. He insisted he could do more, but gave no evidence. The court found he wasn’t a “qualified individual.” - Removing essential functions isn’t required.
He asked the employer to eliminate the physical repair duties—a core part of the job. But the ADA doesn’t require employers to strip away essential functions or reassign them to coworkers. That kind of restructuring fundamentally changes the job and isn’t a reasonable accommodation. - No proof his proposed modifications would work.
He also suggested using assistive equipment like forklifts or cranes. But he didn’t show how he could safely operate them given his restrictions. Without medical or practical support for that proposal, the court found it wasn’t a workable solution. - Reassignment wasn’t viable.
No open positions were available at the time he was cleared to return—and the employer had no obligation to create one. The ADA doesn’t require employers to displace other workers or invent new jobs to accommodate a returning employee. - Leave had limits.
He received over a year off, including two extensions. He offered no proof that more time would help. As the court put it, “an employer’s duty to reasonably accommodate a disabled employee does not require the employer to wait indefinitely for an employee’s medical condition to be corrected.” Employers can say no to open-ended leave requests when there’s no clear timeline for return.
💼 What Employers Can Learn
✅ Use and enforce clear job descriptions. They were pivotal in proving the employee couldn’t perform essential functions.
✅ Engage, don’t indulge. You must explore accommodations in good faith—but not accept every demand.
✅ Know your limits. You don’t have to eliminate core duties, create a new role, or offer indefinite leave.
One last thing:
ADA failure-to-accommodate claims aren’t about whether you made the perfect decision. They’re about whether you acted in good faith, engaged in a flexible, interactive process, relied on documentation (e.g., medical records and job descriptions), explored reasonable options, and made evidence-based decisions. That’s what courts look for—and in this case, that’s what the employer delivered.