6th Circuit: Unpaid ADA Leave Reasonable for Guide Dog Training

The 6th Circuit held that a school district did not violate the ADA by requiring a teacher to use unpaid leave for guide dog training. The court found the teacher failed to identify any nondisabled employees who received paid sick leave when their proposed absence did not qualify for that leave.

Court Determination

The appeals court determined the teacher could not point to any examples of nondisabled employees who were granted paid sick leave “even when the employee’s proposed absence did not qualify for that leave.” This comparison formed the basis for the decision that unpaid leave was reasonable.

Case Background

The case involved a school district worker seeking paid leave under the ADA for time to train a guide dog. The 6th Circuit reviewed whether the district’s refusal to provide paid leave constituted a violation. According to HR Dive, the court focused solely on the absence of comparator evidence from nondisabled employees.

The Americans with Disabilities Act requires employers to provide reasonable accommodations to qualified individuals with disabilities. Under this framework, the 6th Circuit assessed whether the proposed accommodation of paid leave was required.

Implications for Leave Policies

According to HR Dive, the ruling turned on the lack of evidence that other employees received paid leave outside qualifying circumstances. The decision provides a specific example of how courts evaluate comparator evidence in ADA leave disputes.

The 6th Circuit’s analysis centered on the exact language of the teacher’s request and the district’s existing paid sick leave rules. No other factual findings regarding injury counts, penalty amounts, or additional accommodations were part of the published decision.