Navigating reasonable accommodations under the Americans with Disabilities Act (ADA) and related state laws can be challenging for employers—particularly on the thorny issues of leave and remote work. The U.S. Court of Appeals for the Fourth Circuit, in the case of Coffman v. Nexstar Media Inc., offers some guidance on these topics.

• The U.S. Court of Appeals for the Fourth Circuit provided guidance in a recent unpublished opinion on leave and remote work as reasonable accommodations under the ADA and West Virginia Human Rights Act.
• Indefinite leave is not a reasonable accommodation as a matter of law.
• Remote work is not a reasonable accommodation for an employee who is receiving short-term disability insurance benefits, which typically are awarded only when an employee cannot work at all.

The employer approved eight weeks of remote work for an account manager experiencing pregnancy complications, followed by twelve weeks of Family and Medical Leave Act (FMLA) parental bonding leave after she gave birth to twins. Due to severe childbirth-related complications, the employee required surgery that imposed significant physical restrictions, and she was approved for short-term disability (STD) benefits under her employer’s STD policy through her anticipated return date.

When the employee failed to return as expected, the employer contacted her. The employee stated she remained unable to work, that her STD benefits had been extended, and directed the employer not to contact...

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