Definite Medical Leave as a Viable ADA Accommodation: Eleventh Circuit Clarifies “Qualified Individual” Status

Introduction

In Spencer Bueno v. Arhaus, LLC, the United States Court of Appeals for the Eleventh Circuit vacated a district court’s summary-judgment ruling that had dismissed an ADA discrimination claim brought by Spencer Bueno, a sales design consultant who was terminated after taking a three-week stress- and anxiety-related leave. The appellate court held that the lower court erred in treating Bueno’s finite leave request as an impermissible “indefinite leave” and in concluding that he was not a “qualified individual” under the Americans with Disabilities Act (ADA). The ruling re-delineates the boundary between indefinite and definite medical leave and, by doing so, carves out a new, employee-favorable precedent within the Eleventh Circuit: a concrete return-to-work date supported by competent evidence may suffice to survive summary judgment on the “qualified individual” element, even when the employer previously relied on absenteeism policies to justify termination.

Parties:

Plaintiff-Appellant: Spencer Bueno, former design consultant.
Defendant-Appellee: Arhaus, LLC, an upscale furniture retailer.

Key Issue on Appeal: Whether an employee who presents a doctor’s note specifying a finite return date is a qualified individual under the ADA, thereby precluding summary judgment for the employer.

Summary of the Judgment

The Eleventh Circuit held:

The district court correctly found evidence that Arhaus regarded Bueno as disabled.
However, the lower court improperly concluded that Bueno sought an indefinite leave. Because Bueno’s physician set a firm return date of February 21, 2022, and because Bueno testified he was prepared to work that day, a genuine dispute of material fact existed as to his status as a “qualified individual.”
Consequently, summary judgment was inappropriate; the case is vacated and remanded for further proceedings, including consideration of the remaining McDonnell Douglas steps (legitimate reason and pretext).

Analysis

Precedents Cited and Their Influence

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) – established the three-step burden-shifting framework for discrimination claims. The Court emphasized that the district court stopped at the prima facie stage and therefore never assessed Arhaus’s proffered reasons or pretext.
Wood v. Green, 323 F.3d 1309 (11th Cir. 2003) – held that indefinite leave is not a reasonable ADA accommodation. The district court had relied heavily on Wood; the Eleventh Circuit distinguished it because Bueno’s leave was limited in time.
Duckett v. Dunlop Tire Corp., 120 F.3d 1222 (11th Cir. 1997) – found a ten-month and potentially ongoing leave unreasonable. The panel highlighted that unlike Duckett, Bueno had already been on leave for only three weeks and expressed readiness to return.
Frazier-White v. Gee, 818 F.3d 1249 (11th Cir. 2016) – declared an open-ended “light duty” extension request indefinite; again distinguished for lacking a clear end date.
Other procedural / evidentiary authorities: Baker v. Upson Reg’l Med. Ctr. (summary-judgment standard), Feliciano v. City of Miami Beach (crediting a plaintiff’s testimony unless utterly implausible), and Holly v. Clairson Indus. (essential-function analysis).

Legal Reasoning

1. Prima Facie Inquiry. The Court conducted only the first step of McDonnell Douglas because the district court never reached steps two or three. It agreed that the “disability” prong was satisfied under the “regarded as” theory but diverged on the “qualified individual” prong.

2. “Qualified Individual” Analysis. Under 42 U.S.C. §12111(8), two sub-inquiries apply: (a) essential job functions; and (b) whether the employee can perform them with or without reasonable accommodation. The district court deemed regular attendance an essential function and concluded that Bueno’s absence made him unqualified. The appellate court did not dispute that attendance is essential, but emphasized that a time-limited leave can itself be the reasonable accommodation that enables later performance of essential functions.

3. Finite vs. Indefinite Leave. Citing Wood, Duckett, and Frazier-White, the panel reiterated that indefinite leave is per se unreasonable, but distinguished those cases because:

Bueno’s doctor set a specific return date (February 21).
Bueno testified he was “dressed and ready” to work on that date.
No record evidence conclusively contradicted his testimony; conflicting timestamps about WhatsApp removal created issues of fact, not law.

4. Summary Judgment Standards. All factual inferences go to the non-movant; credibility determinations are improper absent video-type contradictions. By crediting Arhaus’s “no-call-no-show” narrative and discounting Bueno’s chronology, the district court resolved genuine factual disputes—an error under Rule 56.

Potential Impact of the Decision

Clarification for Employers and Employees: Requests for medical leave with an objectively verifiable end date are presumptively not “indefinite.” Employers cannot rely reflexively on attendance policies to defeat ADA claims at the summary-judgment stage.
Litigation Strategy Shift: Plaintiffs in the Eleventh Circuit can now survive summary judgment by producing modest evidence (e.g., doctor’s note + testimony) of a definite return-to-work date.
HR Policy Review: Companies may need to revise “no-call-no-show” or rigid attendance policies to incorporate individualized assessments consistent with the ADA interactive-process duty.
Circuit Harmonization: The opinion aligns the Eleventh Circuit with other circuits (e.g., Fifth, Ninth) that have recognized finite medical leave as a potential reasonable accommodation.

Complex Concepts Simplified

Summary Judgment: A procedural device allowing courts to resolve a case without trial when no material facts are in dispute. At this stage, the court must believe the non-movant’s evidence unless it is “blatantly contradicted.”
Prima Facie Case: The initial “minimal” showing a plaintiff must make to shift the burden of production to the employer.
Qualified Individual: An employee who can perform the core duties of the job, now or in the immediate future, with or without accommodation.
Reasonable Accommodation: A change in the workplace or in the way things are usually done that enables a person with a disability to perform essential job functions (e.g., modified schedule, finite medical leave).
Indefinite vs. Definite Leave: “Indefinite” means uncertain or open-ended duration (impermissible under the ADA). “Definite” means supported by a specific timeframe and medical opinion (potentially permissible).
“Regarded As” Disabled: Protection for individuals an employer perceives as having a physical/mental impairment, regardless of actual limitation severity.

Conclusion

Spencer Bueno v. Arhaus, LLC crystallizes an important nuance in ADA jurisprudence: finite, medically documented leave distinguishes a qualified individual from one requesting impermissible indefinite leave. By vacating summary judgment, the Eleventh Circuit reinforces Rule 56 safeguards and clarifies that employers must engage with concrete leave requests rather than dismiss them out of hand. In the broader legal landscape, the opinion encourages balanced consideration of attendance policies against the ADA’s mandate for reasonable accommodation, ensuring that employees who can return on a date certain are afforded their day in court.