Juday v. FCA US LLC

Federal 7th Circuit Court
Civil Court
Family and Medical Leave Act
Citation
Case Number: 
No. 21-1414
Decision Date: 
January 12, 2023
Federal District: 
S.D. Ind., Indianapolis Div.
Holding: 
Affirmed

Dist Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s FMLA action, alleging that defendant interfered with his FMLA rights and retaliated against him for using FMLA leave, when defendant suspended him for 30 days for providing false or misleading information in connection with his FMLA leave requests, where: (1) investigation revealed that more than half of plaintiff’s FMLA absences and half of his late days were on same date and at same time that plaintiff’s wife, who was also employee of defendant, had taken her FMLA leave; and (2) plaintiff had indicated that his wife’s irritable bowel syndrome flare-ups, which formed basis of her FMLA leave requests, would trigger plaintiff’s anxiety 20-30 percent of time, and that plaintiff’s medical conditions would also randomly intensify. FMLA does not insulate employee for abusing his leave rights, and nothing in record called into question defendant’s honest suspicion that plaintiff had abused his FMLA leave. Moreover, plaintiff failed to provide any explanation for frequency of common dates and times of plaintiff’s and his wife’s FMLA absences. As such, plaintiff could not proceed on either his FMLA interference or retaliation claims.