Teryl James, a former FedEx Freight employee, has partially won his appeal against FedEx after being terminated in 2020. The Eleventh Circuit Court of Appeals reversed a lower court’s decision granting summary judgment to FedEx on James’ claim of interference under the Family and Medical Leave Act (FMLA). However, the court upheld the summary judgment on James’ claims of FMLA retaliation and associational discrimination under the Americans with Disabilities Act (ADA).
Background of the Case
James worked for FedEx as a freight handler from 2017 to 2020. In March 2020, he informed his supervisors that his wife was pregnant. Shortly after, he inquired about FMLA leave. Later, in June 2020, his wife’s doctor declared her pregnancy high-risk, requiring her to stop working and needing James to care for her. James notified his supervisors that he might need to leave early or miss work to care for his wife.
On June 25, 2020, James told a supervisor he needed to leave at the end of his shift. Despite completing his assignments, he was asked to work overtime, which he refused due to his wife’s condition. He was then given a “coaching session” for refusing to work overtime. On July 1, 2020, a similar incident occurred; James clocked out after his shift, but his supervisor stopped him and told him to come to the office to talk. James explained his wife’s health complications and that he needed to leave, but was told this would be considered job abandonment. He left anyway. As a result, FedEx terminated James’ employment.
His wife delivered their baby prematurely on July 2. James then applied for and received paid parental leave from July 6 to 17. On July 20, he submitted FMLA paperwork for additional leave, which was approved. However, that same day, FedEx informed him he was under investigation for job abandonment and subsequently terminated him.
The Court’s Decision
The district court had initially granted summary judgment to FedEx on all of James’ claims, finding that he had failed to properly dispute FedEx’s factual assertions and that his claims lacked merit.
The Eleventh Circuit agreed that the district court did not err in admitting FedEx’s statement of facts due to James’ failure to properly dispute them according to court rules. However, the appellate court disagreed with the lower court’s ruling on the FMLA interference claim.
FMLA Interference Claim: A Genuine Dispute of Material Fact
The court found that a genuine dispute of material fact existed regarding James’ FMLA interference claim. To succeed on this claim, James needed to show that he was entitled to a benefit under the FMLA and that FedEx denied him that benefit.
The court reasoned that James presented enough evidence to create a genuine dispute as to whether his wife needed care, which is a qualifying reason for leave under the FMLA, and that FedEx had notice of this need. The court emphasized that James had informed his supervisors about his wife’s condition and his need to care for her.
The court noted that FedEx argued James was fired for failing to check in with a supervisor, not for refusing overtime. However, the court found FedEx’s own communications undermined this argument. A coaching session memo stated James was reprimanded for refusing to unload another trailer because he was on his 8th hour of duty and that he was required to work overtime when needed.
The court concluded that a reasonable jury could find that James was reprimanded and ultimately fired for refusing to work overtime to care for his wife, who was experiencing pregnancy complications. Because FedEx failed to notify James of his FMLA rights, this interference prejudiced James. Had James used the FMLA leave he was entitled to, he would not have been fired for refusing to work overtime.
FMLA Retaliation and ADA Associational Discrimination Claims Fail
The court upheld the summary judgment against James on his FMLA retaliation and ADA associational discrimination claims. To prove FMLA retaliation, James had to show that FedEx intentionally discriminated against him for exercising his FMLA rights. The court found that James failed to show a causal connection between his FMLA-protected activity and the adverse employment actions. He was disciplined for not checking in with a supervisor both before and after his wife became pregnant.
To establish a prima facie case of associational discrimination under the ADA, James needed to show that his wife’s disability was a determining factor in FedEx’s employment decisions. The court found that James could not make the required showing.
Looking Ahead
The case will now return to the district court for further proceedings on the FMLA interference claim. This means a jury will likely hear the evidence and determine whether FedEx interfered with James’ FMLA rights, ultimately leading to his termination. This ruling highlights the importance of employers understanding and complying with their obligations under the FMLA, especially regarding providing employees with notice of their rights.