Circuit Court of Appeals said Wednesday. The plaintiff allegedly received no further follow up and remained on unpaid leave for 16 months before resigning. Orkin won summary judgment on the plaintiff’s disability discrimination and failure-to-accommodate claims, but the 4th Circuit reversed on the latter. The decision is interesting given past court rulings involving both reassignment and unpaid leave under the ADA. In that case, the court said unpaid leave was a suitable accommodation, even if it was not the plaintiff’s preferred accommodation.