EEOC Settles Two ADA Suits Over Return to Work Restrictions

Federal regulators announced two ADA settlements in two days, both involving a worker who sought to return from medical leave with restrictions and was fired instead. The alleged conduct is not identical. In the Maryland case the EEOC says the employer told the worker he could return only if he had no restrictions. In the Florida case the recited allegations describe a firing that followed an accommodation request, and the "100% healed" label comes from an EEOC official's statement rather than from the alleged facts. The EEOC resolved each by consent decree, for $150,000 and $112,500 (D. Md. No. 1:25-cv-04297; S.D. Fla. No. 9:26-cv-81322-EA).

Information last verified on November 9, 2026. This is a developing story; we update it as the record changes.

Scope of this article. This covers federal law under Title I of the ADA as the EEOC enforces it, plus the two specific suits filed in the U.S. District Court for the District of Maryland and the U.S. District Court for the Southern District of Florida. It does not cover state disability statutes, workers' compensation, or the Family and Medical Leave Act, and it does not evaluate any reader's own situation. For the state-law backdrop on firings, see our state-by-state guide to termination claims.

What Happened

On November 4, 2026, the EEOC announced that CBAC Borrower, LLC, Caesars Baltimore Management Co., LLC, and Caesars Entertainment, Inc., doing business together as Horseshoe Casino, would pay $150,000 and provide other equitable relief to settle a disability discrimination and retaliation suit. The agency filed the case as EEOC v. CBAC Borrower, LLC, et al., Case No. 1:25-cv-04297, in the U.S. District Court for the District of Maryland, after first attempting a pre-litigation settlement through its administrative conciliation process.

The casino at issue is the Horseshoe Casino in Baltimore, Maryland, not any similarly named property elsewhere. According to the agency's account of its lawsuit, a man who worked there as a table games dealer suffered a heart attack at work and then underwent surgery. When he asked about returning, the release states, the casino said he could return only if he had no restrictions, failed to engage in the interactive process for providing job accommodations, fired him, and refused to reinstate or rehire him.

The three-year consent decree enjoins the casino from discriminating on the basis of disability and from retaliating and interfering with rights secured by the ADA. It also requires training for management and non-supervisory employees and provides for monitoring and reporting.

"Federal law prohibits employers from refusing to allow disabled employees to return to work because they have disability-related restrictions and it requires them to engage in an interactive process to identify and provide reasonable accommodations."

Source: EEOC press release, "Horseshoe Casino and Caesars Entertainment Companies to Pay $150,000 in EEOC Disability Discrimination and Retaliation Lawsuit," Nov. 4, 2026, quoting EEOC Philadelphia Regional Attorney Debra Lawrence.

A day later, on November 5, 2026, the EEOC announced that Schumacher Auto Group, Inc., a Palm Beach County car dealership company, would pay $112,500 and implement policy and training reforms. That case is EEOC v. Schumacher Auto Group, Inc., Case No. 9:26-cv-81322-EA, in the U.S. District Court for the Southern District of Florida, also filed after conciliation.

The agency's account is narrower on its face than the Maryland one. It states that Schumacher terminated an accounting clerk in May 2024 while the employee was on leave recovering from cancer-related surgery, and that the employee was fired when she requested reasonable accommodations in order to return to work. The accommodations described are a five-pound lifting restriction and no repetitive squatting, bending or lifting for three weeks.

The release's factual paragraph does not allege a written no-restrictions rule at Schumacher. It is the agency's own characterization, in a quote from its Miami District Director, that places the case in that category.

"This case illustrates the harm caused when an employer applies a blanket '100% healed' policy to an employee seeking to return to work with medical restrictions. The ADA requires employers to consider each employee's individual circumstances and determine whether a reasonable accommodation would allow the employee to perform the job."

Source: EEOC press release, "Schumacher Auto Group to Pay $112,500 in EEOC Disability Discrimination Lawsuit," Nov. 5, 2026, quoting EEOC Miami District Director Evangeline Hawthorne.

Under the four-year consent decree, Schumacher will pay $112,500 in compensatory damages to the former employee, implement a comprehensive disability accommodation policy, provide regular training to managers and employees, and report complaints and accommodation requests to the EEOC. EEOC Miami Regional Attorney Kristen Foslid is also quoted, crediting the company's willingness to resolve the matter at an early stage.

Two points of restraint are worth stating plainly. First, neither release reports that the defendants conceded anything; the Maryland release describes "such alleged conduct" and the Florida release describes what happened "according to the EEOC's suit." A negotiated decree is a resolution of contested allegations, not an adjudication of liability. Second, neither release gives a date on which a judge signed or entered the decree, so the entry date is simply not on the public record we reviewed.

The EEOC's newsroom index shows several other settlements and suits announced in the same stretch of early November 2026, across race, harassment and other statutes. The agency has not announced a named initiative on return-to-work policies, and nothing in these two releases claims one.

What the Law Actually Says

Title I of the ADA makes it unlawful for a covered entity to "discriminate against a qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment." That is 42 U.S.C. 12112(a). A "qualified individual" is defined at 42 U.S.C. 12111(8) as someone who, with or without reasonable accommodation, can perform the essential functions of the position held or desired.

Two subsections do the work in a return-to-work dispute. Section 12112(b)(5)(A) defines discrimination to include not making reasonable accommodations to an otherwise qualified individual's known limitations unless the employer shows undue hardship. Section 12112(b)(5)(B) goes further and reaches "denying employment opportunities to a job applicant or employee who is an otherwise qualified individual with a disability, if such denial is based on the need of such covered entity to make reasonable accommodation." A rule that a worker may not come back while any restriction remains is, by its terms, a denial keyed to the need for accommodation.

Section 12112(b)(6) supplies the second route. It prohibits using "qualification standards, employment tests or other selection criteria that screen out or tend to screen out an individual with a disability" unless the standard is job-related for the position and consistent with business necessity. The EEOC's implementing regulation repeats that at 29 C.F.R. 1630.10(a), and the regulation's interpretive appendix states that the provision applies to all types of selection criteria, "including safety requirements, vision or hearing requirements, walking requirements, lifting requirements, and employment tests." The appendix adds that criteria tied to an essential function still may not exclude a person with a disability who could satisfy them with a reasonable accommodation.

The interactive process sits in 29 C.F.R. 1630.2(o)(3), and its wording is more measured than press coverage usually suggests. The rule says that to determine the appropriate accommodation "it may be necessary for the covered entity to initiate an informal, interactive process," which "should identify the precise limitations resulting from the disability and potential reasonable accommodations that could overcome those limitations." The appendix is firmer about the employer's duty once a request arrives: "Once an individual with a disability has requested provision of a reasonable accommodation, the employer must make a reasonable effort to determine the appropriate accommodation," and that accommodation "is best determined through a flexible, interactive process that involves both the employer and the individual with a disability."

The EEOC has published guidance squarely on no-restrictions return-to-work rules. Its 2016 technical assistance document, Employer-Provided Leave and the Americans with Disabilities Act (OLC Control Number EEOC-NVTA-2016-1, issued May 9, 2016), carries a section headed "100% Healed Policies" stating that an employer will violate the ADA if it requires an employee with a disability to have no medical restrictions where the employee can perform the job with or without reasonable accommodation, unless the employer can show the needed accommodations would cause undue hardship. Its Example 13 is a clerk released to return with a twenty-pound lifting restriction whose job did not require lifting twenty pounds. Read that document for what it is: it states on its face that its contents "do not have the force and effect of law and are not meant to bind the public in any way."

The employer-side limits are real and also statutory. Undue hardship is defined at 42 U.S.C. 12111(10) as significant difficulty or expense measured against listed factors. "Direct threat," at 42 U.S.C. 12111(3), is a significant risk to the health or safety of others that cannot be eliminated by reasonable accommodation, and the leave guidance notes that an employer invoking safety has to meet that standard rather than assert a general worry. Coverage has a floor too: 42 U.S.C. 12111(5)(A) defines a covered employer as one with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year.

Because these were federal ADA cases, the federal administrative charge framework governed how each claim had to reach the agency before it could reach a court. The ADA borrows Title VII's procedures through 42 U.S.C. 12117(a), and 42 U.S.C. 2000e-5(e)(1) sets the administrative charge window at 180 days after the alleged unlawful employment practice, extended to 300 days where the person aggrieved first instituted proceedings with a state or local agency with authority over the practice, or to 30 days after notice that the state or local agency has terminated its proceedings, whichever of those two is earlier. Those are general statutory periods, not advice about any particular situation, and they interact with state deadlines that are tracked separately on our Florida termination law page and our Maryland page on wrongful discharge.

Both states are at-will jurisdictions, which is exactly why the federal hook matters here. At-will employment means an employer generally may end the relationship without cause, but it has never meant without limits; a federal antidiscrimination statute is one of the limits, as explained in our overview of how at-will rules work across the states.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

The money in these two decrees is not the story. A $150,000 payment from the three casino operating entities and a $112,500 payment from a regional car dealer group are, in enforcement terms, unremarkable figures. What makes the pair legible as one event is the question both matters put to an employer: what to do when a worker is ready to come back, but not without restrictions. The agency's position in both is that the ADA calls for a decision about the worker rather than a rule applied to a category, though only the Maryland complaint recites a categorical rule.

A categorical rule is the feature the ADA is built to reach. Whether a worker is a qualified individual turns, at 42 U.S.C. 12111(8), on what the person can do with or without reasonable accommodation. A policy keyed to the presence of any restriction never reaches that question. It also collides directly with 42 U.S.C. 12112(b)(5)(B), which makes the need for accommodation an impermissible basis for denying an opportunity rather than a permissible screen.

There is a second reason a blanket rule is fragile, and it is evidentiary. Under 42 U.S.C. 12112(b)(6) and 29 C.F.R. 1630.10(a), a qualification standard that screens out people with disabilities survives only if the employer shows it is job-related for the position in question and consistent with business necessity. "In question" is doing real work in that phrase. A requirement defended for one job does not transfer to another, and a rule applied uniformly across an organization has to be justified for each position it screens, which is a harder showing than defending a specific physical requirement for a specific role.

The two complaints are not equally detailed, and it is worth saying so rather than flattening them. The Maryland allegations describe an explicit statement that the table games dealer could return only without restrictions, plus a failure to engage, a termination and a refusal to rehire. The Florida allegations describe a termination that followed an accommodation request involving a five-pound lifting limit and a three-week restriction on repetitive squatting, bending and lifting, with the no-restrictions framing supplied by the agency's own commentary rather than the recited facts. A reader should treat the Maryland matter as the clearer illustration of the policy and the Florida matter as an illustration of how short and modest a requested accommodation can be while a termination still follows.

The remedial terms also tell you what the agency thinks fixes this, and both decrees point at documents and training rather than at the individual decision. Florida's four-year decree requires a comprehensive disability accommodation policy, recurring training, and reporting of accommodation requests to the agency. Maryland's three-year decree requires training for non-supervisory employees as well as managers. That reflects a view that the rule usually lives in an HR practice or a leave-administration script, not in one supervisor's judgment. Nothing in either release says what any court would have decided had the cases gone forward, and we make no prediction about any future case.

How This Affects You

For workers, the general shape of federal law is that the operative question is whether the person can perform the essential functions of the job with or without a reasonable accommodation, not whether every medical restriction has lifted. That standard is enforced through the EEOC's administrative charge process rather than by filing suit directly, and the statutory periods above are general, not a deadline calculated for anyone's facts.

For employers, the compliance point is narrow and documentary. A leave-administration script or return-to-work form that requires a full-duty or unrestricted release operates as a qualification standard, and under 42 U.S.C. 12112(b)(6) it has to be defensible for the specific position it screens. Safety concerns run through the direct-threat standard at 42 U.S.C. 12111(3), which is a risk showing, not a preference. Neither decree changes the text of the ADA or any regulation; they are enforcement outcomes in two districts resolving allegations the defendants are not reported to have admitted.

This is general legal information, not legal advice. It covers federal law under Title I of the ADA plus two federal cases in Maryland and Florida, and reflects sources verified on November 9, 2026. Laws change and this story is developing; consult a lawyer licensed in your jurisdiction about your specific situation.

Related articles

• Wrongful termination rules, deadlines and claim types by state
• How Florida handles a contested firing
• Maryland wrongful discharge, in plain terms
• At-will employment and its limits across the states

Last updated: 2026-11-09. This is a developing story; details verified as of 2026-11-09.

Frequently Asked Questions

What is a '100 percent healed' or 'no restrictions' return-to-work policy?

It is an employer rule that a worker on medical leave may not return until a doctor clears the worker with no medical restrictions at all. The EEOC's 2016 leave guidance states that such a requirement violates the ADA where the employee can perform the job with or without reasonable accommodation, absent undue hardship.

Did the EEOC win these two cases in court?

No. Both ended in negotiated consent decrees announced November 4 and November 5, 2026, which resolve the agency's allegations. Neither EEOC release reports an admission of liability or describes the decree as a court finding that the ADA was violated.

Which Horseshoe Casino was involved?

The Horseshoe Casino in Baltimore, Maryland. The suit was filed as EEOC v. CBAC Borrower, LLC, et al., No. 1:25-cv-04297, in the U.S. District Court for the District of Maryland. The release was issued through the EEOC's Baltimore Field Office, and the release states that the agency's Philadelphia District Office has jurisdiction over Maryland.

How much did each employer agree to pay?

The Caesars-affiliated Horseshoe Casino operators agreed to $150,000 plus other equitable relief under a three-year decree. Schumacher Auto Group agreed to $112,500 in compensatory damages to the former employee under a four-year decree.

What does the ADA say about the interactive process?

29 C.F.R. 1630.2(o)(3) says it may be necessary for a covered entity to initiate an informal, interactive process to identify the precise limitations and potential accommodations. The regulation's appendix is firmer, stating that once an accommodation is requested the employer must make a reasonable effort to determine the appropriate accommodation.

Can an employer ever refuse to let someone return with restrictions?

Federal law gives employers defined defenses rather than a blanket rule. Undue hardship is defined at 42 U.S.C. 12111(10), and a safety-based refusal runs through the direct-threat standard at 42 U.S.C. 12111(3), which requires a significant risk that reasonable accommodation cannot eliminate.

Does the ADA apply to every employer?

No. 42 U.S.C. 12111(5)(A) defines a covered employer as a person engaged in an industry affecting commerce with fifteen or more employees for each working day in each of twenty or more calendar weeks in the current or preceding calendar year. State disability laws may reach smaller employers.

What are the federal deadlines for an ADA charge?

The ADA adopts Title VII's procedures through 42 U.S.C. 12117(a). Under 42 U.S.C. 2000e-5(e)(1) a charge must generally be filed within 180 days of the alleged unlawful practice, or, where the person first instituted proceedings with a state or local agency with authority over the practice, within 300 days or within 30 days after notice that the agency terminated those proceedings, whichever is earlier. These are general statutory periods, not a deadline calculated for any individual.

Were these part of a wider EEOC campaign?

The EEOC announced several unrelated settlements and suits in the same week across other statutes, but neither release describes a named initiative on return-to-work policies, and we found no announcement of one.