Quick Hits

• 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 no clear timeline for return.

During the leave, Haack’s supervisors regularly checked in with him, asking about how he was feeling and his return-to-work status. However, Haack never provided a return-to-work date. After more than a year, the commission declined further extensions, posted his position, and eventually terminated his employment. Haack then sued under the ADA, Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), Michigan’s Whistleblower Protections Act (WPA), and the state’s Workers’ Disability Compensation Act (WDCA), alleging various theories of discrimination, failure to accommodate, hostile work environment, and retaliation.

The District Court’s Ruling

The court ruled in favor of the commission, stating that Haack’s ADA discrimination and failure-to-accommodate claims failed because he was not a “qualified individual.” At the time his position was posted and his employment terminated, he was medically restricted from working and had no definite return-to-work date. The only accommodation Haack requested was additional leave; but the court reaffirmed that indefinite leave is not a reasonable accommodation, especially after he had already been on leave for over one year.

Haack’s retaliation claims also failed because he could not prove a connection between his protected activity and termination of employment. The court found no evidence that any decision maker reacted negatively to his leave or had any discriminatory intent. The commission’s reason for the termination—his inability to return to work—was legitimate and not disproven by any evidence. Additionally, the hostile work environment claim under the PWDCRA failed because the alleged conduct, such as routine check-in communications (e.g., “call me please” and “Hi Joe. Are you working tomorrow?) and a meeting he found humiliating, were not tied to his disability and did not amount to severe or pervasive harassment. Thus, the court granted summary judgment in favor of the commission on all counts.

Key Takeaways

This decision has several important implications for Michigan employers:

• Tracking leave carefully: The commission’s documentation of rolling doctors’ notes and leave extensions was critical in showing the reasonableness of the leave.
• Indefinite leave requests remain risky for employees: Courts in the Sixth Circuit consistently reject them as unreasonable.
• Neutral communications are not harassment: Routine check-ins by supervisors, without disability-based hostility, do not establish a hostile work environment.

This case is a strong reminder that although the ADA requires reasonable accommodation, it does not require employers to provide indefinite leave or to retain employees who cannot return to work. For Human Resources professionals and in-house counsel, this case reinforces the importance of consistent documentation, clear communication, and relying on established precedent when managing long-term leave situations.