“No Indefinite Leave” and “Causal‐Proximity” Principles in ADA and Title VII Retaliation Claims

Introduction

This commentary examines the Eleventh Circuit’s decision in Jonathan Trent Massa v. Teamsters Local Union 79 & United Parcel Service, Inc. (No. 23-13855, 11th Cir. Jan. 23, 2025). The plaintiff, Jonathan Massa, a part-time UPS package preloader and Union member, sued UPS and the local union under Title VII and the Americans with Disabilities Act (ADA). He alleged race discrimination, disability discrimination, and retaliation after a serious basketball injury led to prolonged medical leave and his eventual termination. The district court granted summary judgment for UPS and the Union, holding that Massa’s claims were both untimely and without merit. On appeal, the Eleventh Circuit assumed timeliness but affirmed the lack of merit.

Summary of the Judgment

The Court of Appeals affirmed the grant of summary judgment for the defendants. Key holdings:

Timeliness: Although the district court found Massa’s EEOC charges untimely, the Eleventh Circuit assumed timeliness and proceeded to the merits.
ADA Discrimination: Massa could not show he was a “qualified individual” because he was physically unable to perform the essential functions of the preloader position for at least six months post‐injury and never requested a reasonable accommodation.
Reasonable Accommodation: No trigger for UPS’s duty to accommodate because Massa never made a specific request; indefinite leave is not a reasonable accommodation absent a concrete return‐to‐work date.
Retaliation (Title VII & ADA): Massa failed to establish causation. Complaints about race discrimination occurred five months before termination; complaints about benefit cancellation post‐dated the termination decision. Temporal gaps of more than three to four months, without additional proof, defeat a retaliation claim.

Analysis

1. Precedents Cited

Zipes v. Trans World Airlines, Inc. (455 U.S. 385, 393 (1982)) – filing a timely EEOC charge is mandatory but not a jurisdictional prerequisite.
Anderson v. Liberty Lobby, Inc. (477 U.S. 242 (1986)) – standards for summary judgment: no genuine dispute of material fact.
Stewart v. Booker T. Washington Ins. (232 F.3d 844 (11th Cir. 2000)) – de novo review of summary judgment with all favorable inferences to the nonmovant.
Holly v. Clairson Indus., L.L.C. (492 F.3d 1247 (11th Cir. 2007)) – definition of “qualified individual” under ADA.
D’Angelo v. ConAgra Foods, Inc. (422 F.3d 1220 (11th Cir. 2005)) – burden on plaintiff to show ability to perform essential functions.
Frazier-White v. Gee (818 F.3d 1249 (11th Cir. 2016)) – an employer’s duty to accommodate is not triggered without a specific request.
Wood v. Green (323 F.3d 1309 (11th Cir. 2003)) – indefinite medical leave generally not reasonable.
Thomas v. Cooper Lighting, Inc. (506 F.3d 1361 (11th Cir. 2007)) – temporal proximity of three to four months is too remote to support retaliation causation absent other evidence.

2. Legal Reasoning

A. ADA Discrimination “Qualified Individual”
The ADA protects only employees who, with or without reasonable accommodation, can perform the essential functions of their jobs. Here, undisputed evidence showed that the preloader role demanded continuous standing, walking and package handling—tasks Massa could not do for six months. He never asked UPS or the Union for a specific accommodation, such as light duty or early return, so UPS had no obligation to propose one or to extend leave indefinitely.

B. Reasonable Accommodation Duty
Under 42 U.S.C. § 12111(8), an employer must provide a reasonable accommodation only once an employee identifies a disability and requests a specific accommodation. Massa’s notification was of his injury, not of his ability to work or of any accommodation needed. No written or oral request for modified duty or for extended leave until recovery appears in the record, so there was no dispute for trial on accommodation.

C. Retaliation “Causal Link”
To prove retaliation under Title VII or the ADA, the plaintiff must show (1) he engaged in protected activity, (2) suffered an adverse employment action, and (3) a causal connection between the two. Temporal proximity—how quickly the adverse action follows the complaint—can support causation. But a gap of more than three to four months, without more, “fails as a matter of law” to show causation. Massa’s race‐discrimination grievances ended in mid‐August 2019, while the termination was finalized in January 2020—a more than five‐month gap. His later complaints about health‐benefit cancellation occurred only after UPS had already processed his termination. Thus no reasonable jury could infer retaliation.

3. Impact

This decision reinforces several key points for employers, unions, and employees:

Employers are not required to provide indefinite leave as an ADA accommodation when the employee cannot yet pinpoint a return‐to‐work date.
Employees must explicitly request reasonable accommodations in order to trigger an employer’s ADA duties.
To survive summary judgment on discrimination under the ADA, a plaintiff must show he could perform essential job functions with or without accommodation.
Retaliation claims hinge on a close temporal nexus or other evidence of animus. Gaps of three to four months are too remote without additional proof.
Union involvement and settlement offers (e.g., the $250 grievance settlement) do not reset or toll the statute of limitations for EEOC charges.

Complex Concepts Simplified

Summary Judgment: A pre-trial ruling that no genuine factual dispute exists and one side is entitled to judgment as a matter of law.
Essential Functions: The fundamental duties of a job—e.g., standing, lifting—that an employee must perform.
Qualified Individual (ADA): An employee who, with or without reasonable accommodation, can do those essential functions.
Reasonable Accommodation: Adjustments or modifications (like light duty) enabling an employee with a disability to work; triggered only by a specific request.
Temporal Proximity: The time gap between protected conduct (e.g., complaining of discrimination) and an adverse action (e.g., firing); short gaps can imply causation, long gaps generally do not.
Prima Facie Case of Retaliation: The minimal showing that the employee (1) engaged in protected activity, (2) was subjected to an adverse action, and (3) a causal link exists between the two.

Conclusion

The Eleventh Circuit’s decision in Massa v. Teamsters Local 79 & UPS clarifies that:

Absent a specific accommodation request, neither an employer nor a union must propose or grant indefinite medical leave under the ADA.
Employees challenging ADA discrimination must demonstrate ability to perform essential job functions with or without accommodation.
Retaliation claims require close temporal proximity or other evidence of retaliatory animus; multi‐month gaps without such evidence are insufficient.

This ruling provides employers and unions a clearer roadmap for handling accommodation requests and timing issues, while reminding employees of the importance of prompt EEOC filings and explicit accommodation demands.