Unreported / Non-Citable
Background
Isaac Ruelaz worked as a forklift operator at Leprino Foods Company's Lemoore, California plant beginning November 16, 2014. The essential functions included lifting boxes of block cheese, carrying up to 48 pounds, hand stacking, operating a forklift, bending, twisting, and forearm supination/pronation, for about seven and a half hours a day, continuously up to eight hours. On March 12, 2023, he was injured operating his forklift and began medical leave. His restrictions grew more severe, from avoiding repetitive neck bending and a wrist brace in March 2023 to no forklift driving beginning February 22, 2024, and by March 2024 a four-hour daily limit with 10- and 15-pound carrying restrictions.
Between March and August 2023, Leprino held five telephonic meetings with Ruelaz about his restrictions and emailed department heads about accommodating positions, but none were identified. In June 2023 his doctor projected a roughly twelve-month condition. On March 13, 2024, a doctor said that if Leprino could not accommodate his modified duties he would be totally temporarily disabled. On March 15, 2024, his doctor stated the forklift position requires a heavy physical demand level Ruelaz does not meet, and his team reported flare-ups one to three times weekly lasting two hours to all day. On March 28, 2024, a doctor projected six to eight months, expressly subject to change, without reconciling the June 2023 projection.
Ruelaz exhausted his twelve-month job-protected leave on March 22, 2024. Leprino terminated him on April 26, 2024, because he could not perform his essential functions, no position could accommodate his restrictions, and his leave was exhausted. As of March 2026 he remained temporarily totally disabled. He sued under FEHA for disability discrimination, failure to accommodate, failure to engage in the interactive process, retaliation, and failure to prevent discrimination and retaliation, plus wrongful termination in violation of public policy. Leprino moved for summary judgment on all claims; the court heard oral argument on September 28, 2026.
The Court’s Holding
The court granted Leprino's motion for summary judgment on all claims. The central issue was whether Ruelaz could perform the essential duties of his forklift operator position with reasonable accommodation, specifically whether six to eight more months of leave was reasonable. At oral argument, Ruelaz's counsel conceded he could not perform the essential functions without accommodation. A leave of absence can be a reasonable accommodation only if finite, meaning it must be likely the employee can perform his duties when the leave ends; leave is not finite where each doctor's note extends it.
The court found no reasonable inference that the March 2024 projection created a genuine issue of material fact. First, Ruelaz's restrictions had grown more severe over the prior twelve months. Second, the projection did not acknowledge or reconcile the June 2023 twelve-month estimate, and its caveat that it was subject to change amplified that omission. Third, as of October 2026 Ruelaz remained unable to work, and the Ninth Circuit has weighed post-termination inability to perform essential functions in upholding FEHA summary judgment, as in Lawler v. Montblanc N. Am., LLC, 704 F.3d 1235 (9th Cir. 2013).
Because Ruelaz could not show he could perform his essential duties with reasonable accommodation, his disability discrimination claim failed, and his inability to work was a legitimate, nondiscriminatory reason for termination. His failure-to-accommodate, interactive-process, retaliation, and failure-to-prevent claims depended on the same ability and failed too. His derivative wrongful termination claim failed as a matter of law, and punitive damages failed with the underlying claims. The court granted the motion, vacated all currently scheduled dates, and directed the clerk to close the case.
Key Takeaways
- A leave of absence is a reasonable accommodation under FEHA only if finite and likely to let the employee perform essential duties when it ends; repeatedly extended leave is not reasonable.
- A medical projection expressly subject to change that contradicts an earlier projection without explanation may not create a genuine issue of material fact about additional leave.
- Evidence that an employee remains unable to work years after termination can inform whether a contemporaneous recovery projection was reasonable.
- Failure-to-accommodate, interactive-process, retaliation, and failure-to-prevent claims under FEHA all depend on the employee's ability to perform essential functions with or without accommodation.
- Derivative wrongful termination and punitive damages claims cannot survive when the underlying FEHA claims fail on summary judgment.
Why It Matters
This decision shows how courts assess whether extended medical leave is a reasonable accommodation under FEHA when restrictions worsen and medical projections are qualified or contradictory. A plaintiff must offer more than a scintilla of evidence that added leave would enable a return to work, and post-termination evidence of continued inability to work is relevant. Derivative claims such as wrongful termination and punitive damages fall with the underlying FEHA claims.