Dillon v. Maryland-National Capital Park & Planning Commission
258 F. App’x 577 (2007)
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Rule of Law:
An employer who violates the Family and Medical Leave Act (FMLA) may avoid liability for liquidated damages if it can demonstrate it had a good-faith and reasonable belief that its actions did not violate the Act, even if that belief is ultimately found to be incorrect.
Facts:
- Cynthia Dillon was an employee of the Maryland-National Capital Park and Planning Commission (“Commission”).
- Dillon requested leave from her job, asserting it was to care for her grandmother.
- The Commission questioned whether Dillon's relationship with her grandmother and the circumstances of the leave qualified for protection under the FMLA.
- The Commission provided Dillon with several opportunities to provide information to clarify her eligibility for FMLA leave.
- After its inquiry, the Commission determined that Dillon's leave was not protected by the FMLA.
- Subsequently, the Commission terminated Dillon's employment.
Procedural Posture:
- Cynthia Dillon sued the Maryland-National Capital Park and Planning Commission in U.S. District Court for wrongful termination in violation of the FMLA.
- The district court granted in part the Commission's summary judgment motion, dismissing Dillon's claim for liquidated damages.
- The Commission moved in limine to exclude Dillon's post-termination evidence; the district court denied the motion in part.
- The case proceeded to a jury trial, which resulted in a verdict in favor of Dillon.
- The jury awarded Dillon backpay, which the district court later reduced in an amended judgment.
- The Commission filed a renewed motion for judgment as a matter of law, which the district court denied.
- The Commission appealed the denial of its motions and evidentiary rulings to the U.S. Court of Appeals for the Fourth Circuit, and Dillon cross-appealed the dismissal of her liquidated damages claim and the reduction of her backpay award.
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Issue:
Does an employer's reasonable but incorrect belief that an employee's leave is not protected under the FMLA shield the employer from liability for liquidated damages?
Opinions:
Majority - Per Curiam
Yes. An employer is shielded from liquidated damages if it demonstrates that its incorrect determination regarding FMLA coverage was made in good faith and based on a reasonable belief. The court found the record supported the conclusion that the Commission acted reasonably, even if incorrectly. The Commission actively considered whether the FMLA applied and gave the employee, Dillon, multiple chances to clarify her situation and establish her eligibility. Because the Commission demonstrated a reasonable, good-faith basis for its belief that the leave was not FMLA-protected, the district court's decision to deny liquidated damages was not an abuse of discretion, drawing an analogy to the standard used under the Fair Labor Standards Act.
Analysis:
This decision reinforces the high bar for awarding liquidated damages in FMLA cases, treating them as punitive rather than automatic. It clarifies that an employer's procedural diligence—investigating a claim and giving an employee a chance to substantiate it—can shield it from liquidated damages even if its substantive legal conclusion is later overturned by a jury. This holding incentivizes employers to create and follow clear procedures for evaluating FMLA requests, as doing so can significantly mitigate financial risk in litigation. It distinguishes the strict liability standard for the underlying FMLA violation from the fault-based standard required for imposing liquidated damages.
