On August 19, 2025, the U.S. District Court for the Eastern District of Michigan held that an employee was not protected under the Americans with Disabilities Act since he had not been medically cleared to return to work and could not perform his essential job functions. The decision in Haack v. Lapeer County Road Commission highlights the stance of requests for indefinite leave in the Sixth Circuit Court of Appeals.
- On August 19, 2025, the U.S. District Court for the Eastern District of Michigan held that an employee on medical leave was not protected under the ADA since he had not been medically cleared to return to work and could not perform his essential job functions.
- The employer had already granted over a year of leave, so the employee’s request for more open-ended leave was considered unreasonable.
- The court reasoned that neutral and nondisability-based communications from the employer did not support a hostile work environment claim.
Background on the Case
Joe Haack, who worked for the Lapeer County Road Commission in Michigan since 1999, had two serious on-the-job car accidents in 2016 and 2021. These accidents left him with ongoing physical and medical issues. Initially, the commission accommodated his needs by giving him light-duty tasks and arranging alternative transportation when he could not drive. By late 2021, his healthcare providers started issuing rolling medical notes that excused him from work entirely and extended his return-to-work dates with...
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