Family and Medical Leave Act

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7^th Circuit Court of Appeals

Case Name: Marianne Wayland v. OSF Healthcare System

Case No.: 23-1541

Officials: Wood, Kirsch, and Lee, Circuit Judges.

Focus: Family and Medical Leave Act

Wayland contended that her former employer, OSF Healthcare System, violated her rights under the Family and Medical Leave Act (FMLA) by neglecting to adjust performance expectations to accommodate her reduced hours during approved medical leave, subsequently terminating her employment. The Central District of Illinois ruled in favor of OSF, granting summary judgment and concluding that Wayland’s termination was justified based on her performance.

Wayland appealed arguing that there existed a genuine dispute regarding the amount of approved leave she had taken. The Circuit Court concurred, finding that if Wayland’s testimony regarding her leave duration is accepted, a jury could potentially determine that OSF unlawfully failed to modify its performance expectations by appropriately considering her leave period during performance evaluations.

Furthermore, the Circuit Court observed that a jury could reasonably find that OSF interfered with or retaliated against Wayland’s use of leave by maintaining the same standards as when she worked full-time and subsequently terminating her employment for failing to meet those standards. It determined that there was adequate evidence to raise doubts about the legitimacy of OSF’s grounds for terminating Wayland, noting that OSF did not explicitly inform her that poor performance would result in dismissal and established goals that may have been unattainable.

Vacated and remanded.

Decided 02/28/24

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