Court Upholds Employer's Rejection of Employees' Requests for FMLA Leave

6/6/08

A recent decision by the Seventh Circuit Court of Appeals highlights the importance of an employer using uniform procedures to review requests for leave under the Family and Medical Leave Act ("FMLA"). Townsend-Taylor v. Ameritech Services, Inc.

 

Taylor, an Ameritech employee, claimed that the company's procedure for reviewing his FMLA leave request interfered with his FMLA rights. Specifically, Taylor claimed that Ameritech should have (1) provided him with an extension for providing extenuating circumstances for failing to meet the company's 20-day deadline, and (2) allowed him, rather than his doctor, to submit the medical certification form. The court disagreed with the plaintiff, noting that the company had already given Taylor a 15-day extension to show extenuating circumstances for his failure to meet the original deadline. The court found that this was a reasonable amount of time to cure any deficiencies, and that any additional extensions would make the company's deadlines ineffectual. Also, the court ruled that requiring an employee's health care provider to submit the medical certification form was a valid measure for preventing fraud.

 

In the same case, the court held that Taylor's spouse, also an Ameritech employee, did not have a valid FMLA claim. Taylor claimed that Ameritech should have given her more time to submit her medical certification form since her work schedule overlapped with her doctor's office hours. The court stated that Taylor had a duty of diligence to timely submit her medical certification form. Since Taylor breached this duty by not exploring other ways she could have submitted her medical form to her doctor earlier, the court ruled Ameritech did not violate her FMLA rights when rejecting her leave request.

 

This case serves as a reminder to employers that uniformly applying reasonable procedures and deadlines that are consistent with the FMLA can in many cases insulate an employer from liability under the FMLA.