10th Circuit Rules Diagnosis Not Required for ADA Disability Claims
Appeals court reverses dismissal, affirming that employers must accommodate disabilities without formal medical diagnoses.
1Appeals Court Reverses Dismissal
The 10th U.S. Circuit Court of Appeals recently overturned a district court decision that dismissed a disability discrimination lawsuit. The case, brought by the EEOC against A A Appliance, Inc., centers on whether an employee must provide a formal medical diagnosis to trigger protections under the Americans with Disabilities Act.
2Communication of Medical Limitations
The employee requested leave in March 2020 after caring for her son and subsequently falling ill herself. She communicated her symptoms through emails, text messages, and a doctor's note. Despite HR testimony denying a conversation, company phone records confirmed a five-minute call occurred where the employee explicitly detailed her work limitations.
3Diagnosis Not a Prerequisite
The district court initially ruled that the lack of a formal diagnosis meant the employer was not on notice of a disability. The 10th Circuit rejected this, clarifying that the ADA does not require a formal diagnosis. Instead, the focus is whether the employer knows enough to conclude a disability exists.
4Employer Awareness of Condition
Evidence suggested the employer was aware of the employee's ongoing health issues. Notably, the company’s own termination letter acknowledged the possibility of a gastrointestinal disorder. The court concluded this admission could support a jury finding that the company knew the employee was suffering from a disability rather than just feeling unwell.
5Reasonableness of Leave Extensions
The employee requested a few weeks of leave beyond the standard 12-week FMLA entitlement. The court ruled this request was not necessarily unreasonable. Because the employee only sought a brief extension to identify her symptoms, the court found it could be considered a reasonable accommodation under the Americans with Disabilities Act.
6Intersection of FMLA and ADA
This ruling highlights the complex overlap between the Family and Medical Leave Act and the ADA. Federal courts have long recognized that the ADA may require additional leave as a reasonable accommodation even after an employee exhausts their 12-week FMLA entitlement, provided the request is specific and medically supported.
7Precedent and Legal Context
The EEOC has previously pursued similar cases, including a 2022 settlement involving employees fired after requesting one to three weeks of additional leave. However, legal standards vary; for instance, a 2025 4th Circuit decision deemed a request for leave until an indefinite date in the fall as insufficiently specific to be reasonable.
8Implications for HR Compliance
Employers must exercise caution when evaluating leave requests that extend beyond FMLA limits. Relying on the absence of a formal diagnosis to deny accommodations creates significant legal risk. Companies should focus on the information provided regarding work limitations and engage in an interactive process rather than dismissing claims based on incomplete documentation.
Original article: HR Dive — 10th Circuit Rules Diagnosis Not Required for ADA Disability Claims