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FMLA Rights Interference and Retaliation

7th Circuit Court of Appeals

Case Name: Michael Juday v. FCA US LLC

Case No.: 21-1414

Officials: Sykes, Chief Judge, and Kanne and Hamilton, Circuit Judges.

Focus: FMLA Rights Interference and Retaliation

Michael Juday has worked for FCA US LLC (formerly Chrysler) for more than two decades. In 2014 he married his wife Becky, also a veteran FCA employee. The Judays work at the company’s transmission plant in Kokomo, Indiana. In 2017 they submitted medical certifications from their healthcare providers to take intermittent leave from work under the Family and Medical Leave Act (“FMLA” or “the Act”), 29 U.S.C. §§ 2601 et seq., for periodic flare-ups of their serious health conditions.

At the end of that year, FCA’s outside FMLA administrator notified the company that Michael and Becky had frequently taken overlapping periods of FMLA leave. FCA opened an investigation, and neither Michael nor Becky could explain why they had requested FMLA leave on so many of the same dates and times. At the conclusion of the investigation, FCA suspended the couple for providing false or misleading information in connection with their FMLA leave requests. Michael Juday then filed suit accusing FCA of interfering with his rights under the Act and retaliating against him for using FMLA leave. The district judge entered summary judgment for FCA on both claims.

To prevail on his claims for FMLA interference and retaliation, Juday needed to present evidence that would permit a reasonable jury to find that his suspension was not based on an honest suspicion of FMLA abuse. He did not do so.

Affirmed.

Decided 01/12/23

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