In Kadler v West Fraser Mills Ltd, 2026 ABCJ 28, the Alberta Court of Justice dismissed an employee’s wrongful dismissal claim after being terminated for just cause, finding that the employee had failed to adequately justify an extended absence from work and had effectively abandoned his employment. The decision is significant because it clarifies the reciprocal obligations of employees and employers during medical leaves and accommodation processes.
Facts
Mr. Kadler, a Wood Room Operator employed by West Fraser, became upset after learning that he would be required to work during the Christmas shutdown period. Following a confrontation with his supervisor, he provided a doctor’s note stating that he required one month off work due to stress related to his working conditions. His absence ultimately extended to approximately two months. During this period, West Fraser requested additional medical information and directed him to participate in the company’s disability adjudication process through Manulife. Mr. Kadler provided only brief doctor’s notes and did not adequately participate in the disability process. Manulife ultimately closed his claim due to insufficient medical information. The employer eventually terminated his employment.
Employee Obligations Emphasized by the Court
1. Employees must provide sufficient information to justify an absence
The Court held that employees cannot simply provide a vague doctor’s note and remain absent indefinitely. While employees are not required to disclose their diagnosis in every case, they must provide sufficient information to establish:
- that they are unable to work;
- the expected duration of the absence; and
- enough information to allow the employer to assess accommodation or disability benefits.
The Court gave limited weight to the physician’s notes because they amounted to little more than a “bald statement” that the employee was ill and unable to work.
2. The longer and more disruptive the absence, the greater the employee’s obligation to communicate
The Court stressed that the amount of information required depends on the circumstances. Where an absence is prolonged or the surrounding circumstances raise legitimate concerns about its legitimacy, an employee’s obligation to provide further information increases.
In this case, the Court found it significant that:
- the employee had just argued with management over holiday scheduling;
- he had expressed a desire not to work over Christmas; and
- he then immediately commenced a stress leave.
These facts entitled the employer to seek additional information.
3. Employees must cooperate in accommodation and disability processes
The Court emphasized that accommodation is a collaborative process. Employees must actively participate by:
- responding to requests for information;
- completing disability claim documentation;
- cooperating with third-party disability administrators; and
- engaging in discussions with the employer about their status and return-to-work prospects.
Mr. Kadler failed to meet these obligations because he did not provide adequate information to Manulife and declined to meaningfully engage with the employer despite repeated requests.
4. Employees cannot simply declare themselves “off work”
The Court rejected the notion that an employee can unilaterally remove themselves from the workplace merely by obtaining a brief medical note. The employee’s position was effectively summarized as: “I have the doctor’s notes and I’m off.” The Court found that this was insufficient in the circumstances.
The Court held that employees have an obligation to adequately explain and support an extended absence from work, while employers have a reciprocal obligation to provide employees with a reasonable opportunity to do so.
Because West Fraser repeatedly sought information, provided opportunities to explain the absence, and attempted to facilitate the disability process, the employer satisfied its obligations. Mr. Kadler did not. Consequently, the Court found that West Fraser had just cause to terminate or, alternatively, that Mr. Kadler had abandoned his employment.
Practical Takeaway for Alberta Employment Law
Kadler stands for the proposition that an employee on medical leave must do more than provide cursory medical notes. Employees have a continuing duty to communicate, cooperate, and provide sufficient information to substantiate an ongoing absence and facilitate accommodation. Failure to do so may justify dismissal for just cause (absenteeism) or job abandonment.
Always seek legal advice. The above is for information purposes only.
Stephen Dugandzic received his Juris Doctor degree from the University of Alberta in 2013 and is Calgary-based. He previously practised with Bennett Jones LLP and Taylor Janis LLP before founding YYC Employment Law Group in 2018 and Evolution Legal in 2026.
FAQs
Can an employee remain off work indefinitely by providing a doctor’s note?
No. Kadler confirms that a brief doctor’s note alone may not justify an extended absence. Employees must provide sufficient medical information to substantiate their inability to work, particularly where the absence is prolonged or circumstances reasonably call the absence into question.
Does an employee have to disclose their medical diagnosis to their employer?
Not necessarily. Employees are generally not required to disclose a specific diagnosis. However, they must provide enough information to allow the employer to understand the employee’s functional limitations, the expected duration of the absence, and whether accommodation may be required.
What obligations does an employee have while on medical leave?
Employees have an ongoing duty to cooperate in the accommodation and disability management process. This includes:
- Providing timely and sufficient medical information;
- Responding to reasonable employer inquiries;
- Participating in disability benefit processes; and
- Keeping the employer informed about their ability to return to work.
Failure to cooperate may jeopardize the employee’s employment.
Can an employer terminate an employee who fails to participate in the accommodation process?
Potentially, yes. Kadler demonstrates that where an employer makes reasonable efforts to obtain information and facilitate accommodation, an employee’s failure to cooperate or provide adequate medical support may amount to just cause for dismissal or evidence of job abandonment, particularly if over a prolonged period of time.
What is the key lesson from Kadler v West Fraser Mills Ltd. for employees?
The key lesson is that accommodation is a two-way street. Employees cannot simply provide cursory medical notes and disengage from the workplace. They must actively participate in the accommodation process, communicate with their employer, and provide sufficient information to support an ongoing absence from work.