West Case Update

Leave Qualifies for FMLA Leave Whether Declared as Such by Employer or Not

Description Supreme Court held that an employer did not violate the Family and Medical Leave Act when it allowed an employee to take more than 12 weeks of unpaid medical leave but did not inform the employee that the leave would count as FMLA leave. The employee had exhausted FMLA leave whether it was declared FMLA leave in advance or not.

Topic Employment Law

Key Words Family and Medical Leave Act; Designated Leave

C A S E S U M M A R Y

Facts Ragsdale began working at a Wolverine factory in 1995. Falling ill in 1996, Wolverine granted her 30 weeks of leave. At the end to that time, she requested more leave, but Wolverine refused and terminated her when she did not return to work. She sued, contending that the Family and Medical Leave Act (FMLA) had been violated. She contended that under the FMLA she was due another 12 weeks of leave. Wolverine had not informed her that the 30 weeks she had already taken would count against the 12 weeks leave required in such cases by the Act, as would be required under a Department of Labor regulation interpreting the law. The district court and court of appeals held for the employer; Ragsdale appealed.

Decision
Affirmed. The FMLA guarantees qualified employees 12 weeks of unpaid leave each year. The law provides punishment for an employer who refused to notify employees of their right to such leave or if an employee is improperly denied leave. The Department of Labor regulation is invalid because it goes beyond requirements set by the statute. Wolverine had allowed Ragsdale to take more than 12 weeks of leave. The fact that Wolverine did not specifically designate, in advance, that the leave taken was FMLA leave, does not mean that Wolverine has violated the statute by not allowing her to take another 12 weeks.

Citation Ragsdale v. Wolverine World Wide, Inc., 122 S. Ct. 1155 (Sup. Ct., 2002)

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Leave Qualifies for FMLA Leave Whether Declared as Such by Employer or Not
Description	Supreme Court held that an employer did not violate the Family and Medical Leave Act when it allowed an employee to take more than 12 weeks of unpaid medical leave but did not inform the employee that the leave would count as FMLA leave. The employee had exhausted FMLA leave whether it was declared FMLA leave in advance or not.
Topic	Employment Law
Key Words	Family and Medical Leave Act; Designated Leave
C A S E S U M M A R Y
Facts	Ragsdale began working at a Wolverine factory in 1995. Falling ill in 1996, Wolverine granted her 30 weeks of leave. At the end to that time, she requested more leave, but Wolverine refused and terminated her when she did not return to work. She sued, contending that the Family and Medical Leave Act (FMLA) had been violated. She contended that under the FMLA she was due another 12 weeks of leave. Wolverine had not informed her that the 30 weeks she had already taken would count against the 12 weeks leave required in such cases by the Act, as would be required under a Department of Labor regulation interpreting the law. The district court and court of appeals held for the employer; Ragsdale appealed.
Decision	Affirmed. The FMLA guarantees qualified employees 12 weeks of unpaid leave each year. The law provides punishment for an employer who refused to notify employees of their right to such leave or if an employee is improperly denied leave. The Department of Labor regulation is invalid because it goes beyond requirements set by the statute. Wolverine had allowed Ragsdale to take more than 12 weeks of leave. The fact that Wolverine did not specifically designate, in advance, that the leave taken was FMLA leave, does not mean that Wolverine has violated the statute by not allowing her to take another 12 weeks.
Citation	Ragsdale v. Wolverine World Wide, Inc., 122 S. Ct. 1155 (Sup. Ct., 2002)