Family Medical Leave CASE SUMMARY
JANET M. RIDINGS, v. RIVERSIDE MEDICAL CENTER
The Family and Medical Leave Act (FMLA) is designed to allow for employees to take unpaid, job-protected leave from their job in the event of a serious and persistent family or medical situation.
Although the law was written to handle numerous situations, federal courts often hear FMLA-related cases involving a dispute between an employer and their current or former employee.
In one 2008 case, federal appellate court dismissed a lawsuit brought by an worker who was terminated after she declined to offer medical documentation validating her necessity for a decreased work schedule.
In the case Ridings v. Riverside Medical Center, Janet Ridings was working for Riverside Medical Center (RMC) when she was diagnosed a thyroid condition called Graves' disease. When her doctor recommended to her to get her thyroid gland removed, Ridings requested and was given three weeks of unpaid time off under FMLA. When Ridings came back to work, she learned that the medication for her condition caused her to feel extremely exhausted by the end of the day. Because of this, she did not work beyond 4:30 p.m. on many days but frequently took work home at night and on weekends.
About one year after her surgical procedure, Ridings' supervisor informed her that she had to start working a complete eight-hour day. When Ridings continued working that schedule, her supervisor wrote up a "corrective action report" saying that her attendance was unsatisfactory, she must start working normal eight-hour days and informing her that if she did not conform a warning would be put into her personnel file. Ridings signed the report, but also supplied a note from her doctor declaring that she could not work an eight-hour day. One week later, Ridings' supervisor said that by using a doctor's note she must give RMC the appropriate FMLA paperwork, along with a leave application and a medical validation form.
On April 21, Ridings’ supervisor issued a second remedial action report on the grounds that she had failed to finish the FMLA paperwork in the required 15-day period. The report also mentioned that if Ridings did not submit the paper work by April 28, she would be suspended for three days. If sh did not turn in paperwork after that, she might be fired.
Ridings did not turn in the paperwork and, on May 10, her supervisor gave her a third report. When she came back from her suspension without the paperwork, Ridings was fired. She then took legal action against RMC claiming unlawful FMLA violations. The initial judge dismissed the case and Ridings appealed.
The Seventh Circuit Court of Appeals learned that the first report Ridings’ supervisor gave failed to inform her that she might be eligible for leave and that the supervisor was unresponsive to a request for clarification on what was needed from her physician. However, the Seventh Circuit ruled that this was not "interference," especially given that RMC later supplied Ridings with the necessary FMLA paperwork and with "ample opportunity" to offer more medical data.
The court rejected Ridings' argument that the doctor's note she presented to her boss was sufficient medical validation. The note did not inform RMC of the expected period of time of her leave, the court discovered. And, even if the note might be considered "certification," the court said, RMC had given Ridings a reasonable opportunity to offer the more data.
Ridings then contended that RMC's policies did not support disciplinary action against her. Considering RMC's leave policies, the court learned that Ridings' absences occurring after RMC requested that she finish the FMLA paperwork were not FMLA-excused. Thus, the court decided that because company policy stated termination as a possible penalty for unnecessary absenteeism, letting her go was not unlawful.
Ridings also contended that RMC unlawfully retaliated against by terminating her for working a decreased schedule, which is considered an FMLA violation. Ridings stated that since she could work at home, she did not have to be on leave. However, the court discovered that she never requested permission to work from home. RMC, which gave Ridings the choice of doing work eight hours on the premises or finishing the FMLA paperwork, was eligible for ask Ridings to work a typical schedule. The court further stated that "an employee cannot simply inform the employer when and from where she would like to work."
Given that RMC was able to ask Ridings to confirm her need for a decreased schedule, gave her quite a number opportunities to supply the requested data, and fired her in accordance with FMLA laws, the court dismissed Ridings' retaliation claim as well.
FMLA Laws and Prevailing in an FMLA Court Case
The FMLA allows a qualified worker up to 12 weeks of unpaid leave within a 12-month period where the worker has a significant health condition that renders them unable to perform the functions of their position. The FMLA also permits the worker to take leave intermittently or on a decreased schedule when medically required. Under the FMLA, it is unlawful for a company to interfere with a worker's attempt to exercise the rights set up by the law. A worker does not need to be aware of their rights in order to invoke them.
To prevail on an interference claim in an FMLA court case, a worker must indicate that their company is guilty of one of a number of FMLA violations. The worker must also identify eligibility for the FMLA's protections, work for an company protected by the FMLA, be qualified to leave under FMLA laws, give enough notice of the intention to take leave, and reveal that and company denied FMLA benefits to which they were entitled.
In an FMLA court case involving retaliation, a plaintiff may proceed under the direct or indirect processes of proof. Under the direct method, a plaintiff must present evidence that her company took a materially adverse action against them on account of their activity protected under FMLA laws. A plaintiff can prevail under the direct method by showing an admission of discrimination or by building a convincing case that allows a jury to “infer intentional discrimination by the decisionmaker.”