Severson v. Heartland Woodcraft, Inc.

Raymond Severson (plaintiff) worked for Heartland Woodcraft, Inc. (Heartland) (defendant), a company that fabricated retail-display fixtures, from 2006 to 2013 in various physically demanding roles. Severson suffered from back pain beginning in 2005 and was diagnosed with back myelopathy in 2010. On June 5, 2013, Severson aggravated his myelopathy by wrenching his back at home, making it impossible for Severson to work. Severson began medical leave under the Family and Medical Leave Act (FMLA), which maxed out at 12 weeks. Severson was treated for multiple herniated and bulging discs in his spine. Ultimately, Severson had to schedule surgery for August 27, 2013, the same day that his FMLA leave expired. Severson informed Heartland’s human-resources manager that his surgery’s normal recovery time was at least two months and requested that Heartland extend his medical leave. Heartland instead terminated Severson and invited Severson to reapply at Heartland after he was medically cleared to return to work. Severson did not reapply after his doctor fully cleared him for work. Severson sued Heartland in federal district court, alleging that Heartland had violated the Americans with Disabilities Act (ADA) by failing to reasonably accommodate Severson’s disability. The district court granted Heartland’s motion for summary judgment, finding that none of Severson’s proposed accommodations was reasonable. Severson appealed. The Equal Employment Opportunity Commission (EEOC) filed an amicus brief in support of Severson’s appeal that urged the United States Court of Appeals for the Seventh Circuit to adopt a new rule.