When an employee asks for time off for medical reasons, employers often aren’t sure how much medical detail they’re allowed to ask for, or what their obligations are to accommodate the employee. 

A recent decision from the Human Rights Tribunal of Ontario (HRTO) helps clarify this. It shows that vague medical notes aren’t enough on their own, and that employees need to show they have a protected right under the Human Rights Code to get accommodation. 

What Happened in This Case? 

In Baker v. Firon Roofing Inc., 2026 HRTO 292 (CanLII) the employee worked as an Assistant Office Manager at a small roofing company. Soon after she started, she went on medical leave, and presented a medical note saying she was “totally disabled” for about a month. 

Her employer asked for more details by requesting a Functional Abilities Form (FAF), a standard form that explains what an employee can and cannot do at work. The form was never completed. 

A month later, the employee submitted another similar note extending her leave. The next day, the employer laid her off, saying that an early winter had slowed down business. 

She was never called back to work, and the company eventually eliminated her position, whereupon the employee claimed the real reason for her layoff was her medical leave and filed a human rights complaint. 

What the Tribunal Decided 

The HRTO dismissed her claim, identifying the basic test for discrimination that must be met by an applicant to prove a prima facie case: 

  1. They have a protected characteristic (like a disability) under the Human Rights Code 
  1. They experienced negative treatment (like being laid off) 
  1. The protected characteristic played a role in that treatment 

If all three are proven, the employer then has to explain its decision. 

Simply saying “I’m disabled” isn’t enough 

The Tribunal found the employee failed at the very first step.  

The medical notes only said she was “totally disabled.” They didn’t include: 

  1. a diagnosis 
  1. symptoms 
  1. any explanation of her limitations 

The Tribunal said that just claiming a disability isn’t enough. There needs to be some supporting medical information, and because the employee didn’t provide that information (including not completing the FAF), the employer had no way of understanding her restrictions or figuring out how to accommodate her. 

The layoff had a legitimate business reason 

The Tribunal also said that even if the employee had proven a disability, her claim still would have failed, because the employer showed that: 

  1. business slowed due to early winter 
  1. several employees were laid off 
  1. the company later eliminated her role and restructured 

The Tribunal accepted that these were real, non-discriminatory business reasons. Her alleged disability wasn’t a factor in the decision. 

Key Takeaways 

Here are the practical lessons from this decision: 

For employees 

You only have a right to accommodation if you can show you have a disability under the Human Rights Code. 

A vague doctor’s note saying you can’t work is usually not enough. 

You should provide reasonable medical details (like a FAF) if your employer asks, so they can understand your limitations and explore accommodation. 

For employers 

You are allowed to ask for more information if a medical note is too vague. 

You don’t have to accommodate an employee based only on a basic note with no details. 

Without clear information about restrictions, it’s very difficult to assess accommodation options. 

For both sides 

Even where accommodation is required, employers can still end the employment relationship for legitimate, unrelated business reasons. 

However, if the employee’s disability plays any part in the decision, it could still be considered discrimination. 

Bottom Line 

This case reinforces that accommodation is a shared process: 

Employees must provide enough medical information to support their request. 

Employers must respond reasonably once they have that information. 

Clear, specific medical documentation is key to making the process work—and avoiding disputes. 

If you have questions about how this decision might apply to your workplace, find yourself dealing with a similar situation, or would simply like guidance on medical leaves and accommodation obligations, the team at SpringLaw would be happy to help. We regularly advise both employers and employees on navigating these issues in a practical and strategic way—feel free to reach out to discuss your specific circumstances.