20  ILLINOIS BUSINESS LEADER
EMPLOYMENT LAW
A recent decision from the Fourth 
Circuit Court of Appeals tackled 
the question of when an employer 
is obligated to provide leave as a 
disability accommodation when 
the leave request is for an indefinite 
length of time. In Coffman v. Nexstar 
Media Inc., No. 23-2253 (4th Cir. July 
22, 2025), the Fourth Circuit upheld 
the dismissal of a former employ­
ee’s claims under the West Virginia 
Human Rights Act (WVHRA) and 
the Family and Medical Leave Act 
(FMLA), finding that her request for 
additional leave after a six-month ab­
sence and no definite return date was 
not a reasonable accommodation. 
The Fourth Circuit’s ruling highlights 
that while employers must provide 
reasonable accommodations for 
disabilities, they are not required to 
grant open-ended or indefinite leave 
to satisfy their obligations.
CASELAW BACKGROUND
Coffman was an account executive 
at a Nexstar news station in West 
Virginia. During the employee’s preg­
nancy, she developed serious medical 
complications requiring her to be on 
bedrest. Nexstar allowed her to work 
remotely in the weeks leading up to 
her delivery date. On February 23, 
2022, Coffman gave birth to twins via 
By Laurie E. Meyer
Partner, Amundsen Davis
c-section and was promptly granted 
12 weeks of FMLA leave.
	
A few days into her FMLA leave, 
Coffman learned that she was experi­
encing serious complications from her 
c-section for which she would need 
a series of surgeries. She applied and 
received short term disability (STD) 
benefits, which ran concurrently with 
her FMLA leave and continued to 
run after the employee’s FMLA leave 
ended in mid-May of 2022.
	
By the end of June, Nexstar 
reached out to Coffman as it had 
yet to receive a doctor’s return-to-
work approval. Coffman responded 
by stating she could not provide a 
return-to-work date as she had two 
anticipated upcoming surgeries and 
that “they’re extending [my STD] 
benefits.” When HR clarified that 
STD benefits are not the same as 
job-protected leave, Coffman asked, 
“Do you want to speak to my law­
yer?” She then texted HR: “Please do 
not contact me regarding a return to 
work date when I have been classi­
fied as unable to return and still have 
short-term disability plus bonding 
leave.” She provided her lawyer’s 
contact information.
	
Nexstar’s HR team followed up 
in writing, asking again for a return-
to-work date, and again clarifying 
Extended, Indefinite Leave Request Is Usually  
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While the ADA and most states require employers to 
provide leave as a reasonable accommodation, the 
obligation does not extend to holding a position open for 
an unknown or open-ended return date.
Madison Monroe
Associate, Amundsen Davis

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