Renee Maat v. County of Ottawa, 657 F. App'x 404

Renee Maat was hired in 2007 as a court recorder for Judge Susan Jonas at the 58th District Court (a Michigan trial court financed and administratively supported by Ottawa County).
In late 2010 Maat developed multiple blood clots and intermittent but worsening symptoms; she used intermittent and then part‑time FMLA leave while working a temporary reduced schedule for ~7 months.
In June 2011 Maat’s condition worsened; her physician reported she was "unable to perform work of any kind" and expected further tests, medication trials, and possible surgery, and Maat requested conversion to full‑time medical leave through August 1, 2011.
Court administrators and Ottawa County HR informed Judge Jonas; Judge Jonas decided she needed a permanently credentialed, full‑time recorder and terminated Maat; termination was communicated on Ottawa County letterhead.
Maat sued the 58th District Court and Ottawa County under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), the ADA, and the Rehabilitation Act, alleging failure to accommodate and discriminatory discharge; the district court granted summary judgment for both defendants, and Maat appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether PWDCRA requires employer to grant extended medical leave when employee cannot perform job at discharge	Maat: PWDCRA requires reasonable accommodation, here extension to leave	Defendants: PWDCRA does not protect employees who are unable to perform job duties at time of discharge	Held: PWDCRA does not cover employees unable to perform job at termination; summary judgment for defendants
Whether ADA/Rehabilitation Act required granting additional unpaid leave (full‑time leave to Aug 1, 2011) as a reasonable accommodation	Maat: additional leave was a reasonable accommodation; precedents allow medical leave in some cases	Defendants: requested extension was open‑ended/indefinite and imposed undue hardship; employer reasonably questioned return date	Held: Requested leave lacked a definite, credible end given ongoing treatment and uncertain prognosis; extension was not a reasonable accommodation — summary judgment for defendants
Whether Ottawa County is a joint employer and liable for ADA/Rehab Act violations	Maat: County was joint employer and participated in denial/termination	County: lacked control under state law and did not make termination decision	Held: Court did not resolve employer‑status dispute because Maat failed to show entitlement to relief even if County were joint employer

Lamoria v. Health Care & Ret. Corp., 593 N.W.2d 699 (Mich. Ct. App. 1999) (PWDCRA does not require leave until employee can perform job at discharge)
Kerns v. Dura Mech. Components, Inc., 618 N.W.2d 56 (Mich. Ct. App. 2000) (employer need not grant medical leave until ability to perform job returns)
Cehrs v. Northeast Ohio Alzheimer’s Research Ctr., 155 F.3d 775 (6th Cir. 1998) (medical leave can be a reasonable accommodation where duration and prospect of recovery are definite)
Walsh v. United Parcel Serv., 201 F.3d 718 (6th Cir. 2000) (extension of substantial leave is unreasonable if no clear prospect or definite end date for recovery)
Aston v. Tapco Int’l Corp., [citation="631 F. App'x 292"] (6th Cir. 2015) (requested additional leave beyond lengthy prior leave unreasonable where no certain end in sight)
EEOC v. Ford Motor Co., 782 F.3d 753 (6th Cir. 2015) (en banc) (discusses standards for reasonable accommodation and related analyses)