Joey L. Mitchell v. Glenn Chapman

Rule of Law:

The Family and Medical Leave Act (FMLA) does not impose individual liability on supervisors employed by public agencies. The statutory text of the FMLA separates the definition of 'public agency' from the provision that creates individual liability for those acting 'in the interest of an employer,' indicating congressional intent to exclude public agency supervisors from such liability.

Facts:

• Joey L. Mitchell, an employee of the United States Postal Service (USPS), suffered from chronic neck pain stemming from a prior injury sustained in the U.S. Navy.
• On November 11, 1996, Mitchell's physician certified that his neck condition was a chronic serious illness under the Family and Medical Leave Act (FMLA), necessitating occasional absences from his job as a letter carrier.
• On February 12, 1997, Mitchell submitted a formal request to Postmaster Richard A. Derrickson for a transfer to a less physically demanding clerk position.
• After Mitchell was absent on May 12, 1997, due to his neck injury, his acting supervisor, Glenn Chapman, reprimanded him and stated poor attendance could negatively impact his transfer request.
• Following this exchange, Derrickson ordered Mitchell to undergo a fitness-for-duty examination and temporarily reassigned him to clerk duties.
• Mitchell provided a note from his doctor clearing him to perform his duties, and subsequent medical evaluations confirmed he could work as a letter carrier if he used a waist harness instead of a shoulder satchel.
• Despite the medical clearances, Derrickson did not return Mitchell to his letter carrier position.
• On August 11, 1997, Mitchell submitted a second transfer request to a full-time clerk position, which Derrickson approved, making the transfer effective on August 30, 1997.

Procedural Posture:

• Mitchell contacted an Equal Employment Opportunity (EEO) counselor and later filed a formal EEO complaint, which the USPS dismissed as untimely because he missed the 45-day deadline.
• Mitchell filed his first lawsuit (Mitchell I) in the U.S. District Court for the Eastern District of Kentucky against the USPS, alleging violations of the Rehabilitation Act and the ADA.
• The district court granted summary judgment to the defendants in Mitchell I, holding the claim was barred by Mitchell's failure to timely contact an EEO counselor.
• Nearly a year later, Mitchell filed a second lawsuit (Mitchell II) in the same district court against the USPS and three supervisors individually, asserting FMLA and other civil rights claims.
• The district court granted summary judgment for the defendants in Mitchell II, ruling that claims against the USPS and supervisors in their official capacities were barred by claim preclusion, and that the FMLA does not permit individual liability for public agency supervisors.
• Mitchell, as the Appellant, appealed the district court's grant of summary judgment to the United States Court of Appeals for the Sixth Circuit.