Massey-Diez v. UICMS

Plaintiff, formerly employed at UICSM as a physician assistant, filed suit alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. The district court granted summary judgment to UICSM. The court noted that 29 C.F.R. 825.311(a) inarguably permitted UICMS to contact plaintiff to inquire about her "status and intent to return to work." The court concluded that UICMS was entitled to summary judgment on plaintiff's interference claim where plaintiff has not presented evidence that UICMS's requests for her to work from home when she had a broken foot were a condition of her employment nor that her compliance with them was anything but voluntary. The evidence does not permit a reasonable jury to find that UICMS interfered with plaintiff's right to FMLA leave. In regard to plaintiff's discrimination claim, the court concluded that the sequence of events alone does not give rise to a causal link between UICMS's alleged discriminatory motive and its decision not to renew plaintiff's contract strong enough to permit her to forgo the burden-shifting framework; applying the McDonnell Douglas framework, the court concluded that UICMS has proffered plaintiff's tardy charting as a nondiscriminatory justification for deciding not to renew her contract; and plaintiff has not created a dispute as to pretext. Accordingly, the court affirmed the judgment. View "Massey-Diez v. UICMS" on Justia Law