Run a parallel FMLA and ADA accommodation analysis
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What the employee asked for, on what date, and any medical or family context they shared.
Tenure, hours, and the essential functions of the job as actually performed.
Headcount, worksite footprint within 75 miles, and the operational constraints that bear on coverage.
Drives the mini-FMLA, paid-leave, and accommodation overlay.
Earlier leave taken, accommodations granted or denied, and how comparable requests were handled.
Watch for these throughout
Designation is the employer's obligation, not the employee's. Failing to designate within five business days of having sufficient information can extend the total leave entitlement.
Automatic termination at the end of 12 weeks of FMLA leave is an enforcement priority. ADA leave frequently runs past the FMLA entitlement, and the two questions must be answered separately.
Medical inquiries must be confined to the limitation at issue. A request for complete records or all conditions is itself a violation, whatever the underlying entitlement.
State paid-leave and mini-FMLA programs have independent coverage thresholds, notice rules, and certification forms, and some stack rather than run concurrently. Verify the current program rules. Several states have amended theirs recently.
The PWFA covers pregnancy-related accommodation without an ADA-level disability. If pregnancy appears anywhere in the facts, run that analysis rather than folding it into the ADA track.