Coffman v. Nexstar Media Inc. (4th Cir. 2025): Clarifying that Only “Objectively Reasonable” Accommodation Requests Trigger Protection under the WVHRA

Introduction

Leanna Coffman, an Account Executive for Nexstar Media in Beckley, West Virginia, suffered medical complications arising from the birth of twins. After FMLA leave and several months of short-term disability, Nexstar terminated her employment, prompting Coffman to bring four claims:

• Failure to accommodate under the West Virginia Human Rights Act (WVHRA)
• Discriminatory discharge under the WVHRA
• Retaliatory discharge under the WVHRA
• Retaliatory discharge under the FMLA

The district court granted summary judgment for Nexstar on all counts. The Fourth Circuit, reviewing de novo, affirmed. Although many principles applied are familiar from ADA jurisprudence, the opinion plants an important flag in West Virginia law: a request for an accommodation that is not objectively reasonable does not constitute “protected activity,” and therefore cannot ground a retaliation claim under the WVHRA. The Court also reinforced long-standing limits on indefinite leave and remote-work requests where the employee is medically unable to perform any work.

Summary of the Judgment

1. Failure-to-Accommodate (WVHRA): Coffman proposed three accommodations—extended unpaid leave, paid parental leave, and remote work. Each was held unreasonable on its face:
   • Both paid and unpaid leave would have been indefinite.
   • She was medically incapable of working at all, so remote work would not enable performance of essential functions.
2. Discriminatory Discharge (WVHRA): Because no reasonable accommodation existed, Coffman was not a qualified individual with a disability, failing an essential element of her prima facie case.
3. Retaliatory Discharge (WVHRA): A request that is not objectively reasonable is not a statutorily protected activity; therefore Coffman could not satisfy the first prong of retaliation.
4. Retaliatory Discharge (FMLA): A three-month gap between the end of FMLA leave and termination, coupled with Nexstar’s generous leave extensions, broke any causal chain.

Analysis

Precedents Cited and Their Influence

• Burns v. WV Dep’t of Educ. & Arts, 836 S.E.2d 43 (W.Va. 2019) – set the six-factor prima facie test for failure-to-accommodate claims. Coffman faltered at factor four (existence of a reasonable accommodation).
• Myers v. Hose, 50 F.3d 278 (4th Cir. 1995)
  “Nothing in the text … requires an employer to wait an indefinite period for an accommodation to achieve its intended effect.” This passage undergirded rejection of Coffman’s open-ended leave request.
• Halpern v. Wake Forest Univ. Health Sciences, 669 F.3d 454 (4th Cir. 2012) – confirmed that leave without a defined endpoint is unreasonable; cited for both leave and remote-work analyses.
• Wilson v. Dollar General Corp., 717 F.3d 337 (4th Cir. 2013) & Perdue v. Sanofi-Aventis, 999 F.3d 954 (4th Cir. 2021) – clarified that employers cannot be liable for a breakdown in the interactive process if no reasonable accommodation exists.
• King v. Rumsfeld, 328 F.3d 145 (4th Cir. 2003) – two-plus-month gap significantly weakens inference of FMLA retaliation; applied to find no causal link.

Legal Reasoning of the Court

1. Reasonableness as a Threshold Question.
   The panel treated “reasonableness” as an objective, judicable matter at summary judgment. If a proposed accommodation is facially unreasonable—e.g., indefinite leave or remote work for an employee medically barred from any work—a jury need not decide.
2. No Duty to Provide Indefinite Leave.
   The Court read the WVHRA in pari materia with the ADA. Citing Myers and Halpern, it held that an employer’s duty runs only to accommodations that enable the employee to work presently or in the immediate future. Coffman’s “four-to-six weeks, maybe longer pending another surgery” failed that test.
3. Remote Work Requires Ability to Work.
   Remote work is not a panacea; where the record shows total work incapacity (continuous short-term disability classification), telework adds nothing.
4. Protected Activity Requires a Reasonable Request.
   The Court adopted—at least implicitly—the view that the WVHRA shields only reasonable accommodation requests. An objectively unreasonable or indefinite request falls outside statutory protection, collapsing a retaliation claim at the prima facie stage.
5. Causation Under FMLA Retaliation.
   Temporal proximity remains the principal tool. Three months, combined with the employer’s repeated leave extensions, dissipated any causal inference.

Impact of the Decision

The Fourth Circuit’s unpublished but persuasive opinion reverberates beyond the parties:

• Employers gain clearer guidance that they:
  • Need not hold positions open indefinitely.
  • May treat requests that are facially unreasonable as non-protected for retaliation purposes.
  • Can defeat interactive-process claims by showing no reasonable accommodation was possible.
• Employees are cautioned to:
  • Provide concrete, medically supported return-to-work estimates.
  • Recognize that merely asking for something impossible will not shield them from later adverse action.
• Litigators will likely cite Coffman to argue that:
  • Unreasonable accommodation requests fall outside “protected activity.”
  • Summary judgment can be appropriate where the only proposed accommodation is indefinite leave.
• Policy-wise, the decision nudges West Virginia ADA-analog claims toward a stricter, employer-friendly framework, emphasizing objective feasibility over aspirational flexibility.

Complex Concepts Simplified

• WVHRA vs. ADA. The West Virginia Human Rights Act is a state analogue to the federal ADA. Courts routinely read them in lock-step, so ADA precedents guide WVHRA rulings.
• Reasonable Accommodation. A change in workplace policy or environment allowing a person with a disability to perform essential job functions. It must be effective, feasible, and not impose undue hardship.
• Interactive Process. A cooperative dialogue between employer and employee to identify possible accommodations. However, if no accommodation will work, failure to engage becomes legally irrelevant.
• Indefinite Leave. Leave whose duration has no reasonably ascertainable end point. Courts nearly uniformly deem it unreasonable because it does not enable job performance in the foreseeable future.
• Protected Activity (Retaliation Context). An action statutorily shielded from employer retribution (e.g., filing a discrimination charge, requesting a reasonable accommodation). The Court holds the request must be objectively reasonable to qualify.
• Prima Facie Case. The minimum set of facts that, if unrebutted, entitle a plaintiff to relief. Once established, the burden shifts to the employer to offer a legitimate reason for its action.

Conclusion

Coffman v. Nexstar rearticulates well-worn ADA/WVHRA limits on extended leave and telework, but it also adds a clarifying wrinkle: only objectively reasonable accommodation requests trigger the WVHRA’s anti-retaliation protections. Employers still must carefully engage in the interactive process, but they are not required to indulge uncertain timelines or unworkable proposals. For employees and practitioners in the Fourth Circuit, the case underscores the importance of marrying accommodation requests to concrete medical evidence and feasible timelines. Absent that, even sympathetic circumstances will yield to summary judgment.