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  • In Frazier-White, the Eleventh Circuit held that an employer did not discriminate (hence, the plaintiff failed under prong (3) set forth above) under the ADA or the Florida Civil Rights Act by failing to provide a reasonable accommodation where the employee proposed two accommodations: to allow the employee “an indefinite extension of her light-duty status and reassignment to some other, unspecified position.” Frazier-White v. Gee, 818 F.3d 1249, 1256 (11th 2016). Because of the nature of the plaintiff’s medical condition in Frazier-White v. Gee, the plaintiff did not know and did not suggest a time frame for when she was able to return to her full-duty position. The court found that such an indefinite extension was unreasonable as a matter of law as the ADA is intended to cover people who perform the essential functions of their jobs “presently or in the immediate future.” Wood v. Green, 323 F. 3d 1309, 1314 (11th Cir. 2003). The Eleventh Circuit made clear in Frazier-White v. Gee that while employers are required to make reasonable accommodations under the ADA when doing so they do not, as a matter of law, have to allow an employee to remain on light duty status in perpetuity or create a new job for them. Frazier-White v. Gee, 818 F.3d 1249 (11th Cir. 2016).