b'EMPLOYMENT LAWExtended, Indefinite Leave Request Is UsuallyNOT a Reasonable AccommodationWhile the ADA and most states require employers to provide leave as a reasonable accommodation, the By Laurie E. MeyerPartner, Amundsen Davis obligation does not extend to holding a position open for an unknown or open-ended return date.A recent decision from the Fourthc-section and was promptly granted Circuit Court of Appeals tackled12 weeks of FMLA leave.the question of when an employerA few days into her FMLA leave, is obligated to provide leave as aCoffman learned that she was experi-disability accommodation whenencing serious complications from her Madison Monroe the leave request is for an indefinitec-section for which she would need Associate, Amundsen Davis length of time. In Coffman v. Nexstara series of surgeries. She applied and Media Inc., No. 23-2253 (4th Cir. Julyreceived short term disability (STD) 22, 2025), the Fourth Circuit upheldbenefits, which ran concurrently with the dismissal of a former employ- her FMLA leave and continued to ees claims under the West Virginiarun after the employees FMLA leave Human Rights Act (WVHRA) andended in mid-May of 2022.the Family and Medical Leave ActBy the end of June, Nexstar (FMLA), finding that her request forreached out to Coffman as it had additional leave after a six-month ab- yet to receive a doctors return-to-sence and no definite return date waswork approval. Coffman responded not a reasonable accommodation.by stating she could not provide a The Fourth Circuits ruling highlightsreturn-to-work date as she had two that while employers must provideanticipated upcoming surgeries and reasonable accommodations forthat theyre extending [my STD] Read More Here disabilities, they are not required tobenefits. When HR clarified that grant open-ended or indefinite leaveSTD benefits are not the same as to satisfy their obligations. job-protected leave, Coffman asked, Do you want to speak to my law-CASELAW BACKGROUND yer? She then texted HR: Please do Coffman was an account executivenot contact me regarding a return to at a Nexstar news station in Westwork date when I have been classi-Virginia. During the employees preg- fied as unable to return and still have nancy, she developed serious medicalshort-term disability plus bonding complications requiring her to be onleave. She provided her lawyers bedrest. Nexstar allowed her to workcontact information.remotely in the weeks leading up toNexstars HR team followed up her delivery date. On February 23,in writing, asking again for a return-2022, Coffman gave birth to twins viato-work date, and again clarifying 20ILLINOIS BUSINESS LEADER'