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Ralph Cooper v. Fulton County, Georgia

Court of Appeals for the Eleventh Circuit
2006 U.S. App. LEXIS 20133, 458 F.3d 1282, 11 Wage & Hour Cas.2d (BNA) 1185 (2006)
ELI5:

Rule of Law:

Under the Family and Medical Leave Act (FMLA), when an employee requests unforeseeable leave, an employer must provide written notice of its medical certification requirement and allow the employee at least fifteen calendar days to comply, unless the employer has provided general written FMLA guidance in the preceding six months.


Facts:

  • Ralph Cooper, an employee of Fulton County for nearly twenty years, had a history of depression and health issues that caused repeated absences from work.
  • On June 22, 1998, Cooper went to the hospital for chest pains and was absent from work for several days.
  • On July 6, 1998, the County sent a letter demanding a doctor's note by July 8, which Cooper provided, clearing him to return on July 13.
  • On July 13, Cooper returned to work but left after two hours, telling his supervisor he was too ill to continue.
  • The next day, July 14, Cooper faxed a letter to his supervisor formally requesting family leave due to blurred vision, extreme headaches, and 'passing out.'
  • On August 4, 1998, the County sent Cooper a letter demanding he provide medical certification for his absence by August 10, a six-day deadline.
  • Cooper obtained a doctor's letter on August 7 but did not immediately deliver it.
  • The County sent Cooper a letter on August 10 terminating his employment, and Cooper faxed his doctor's letter to the County the next day.

Procedural Posture:

  • Ralph Cooper sued his former employer, Fulton County, in the United States District Court, alleging a violation of the Family and Medical Leave Act (FMLA).
  • The district court granted summary judgment to Cooper on the issue of liability.
  • After a bench trial on damages, the district court awarded Cooper back pay, pension contributions, and liquidated damages.
  • Fulton County, as the appellant, appealed the judgment to the U.S. Court of Appeals for the Eleventh Circuit; Cooper is the appellee.

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Issue:

Does an employer violate the Family and Medical Leave Act (FMLA) by terminating an employee for failing to provide medical certification within a six-day deadline, when FMLA regulations require at least fifteen days' notice for unforeseeable leave and the employer has not provided prior written guidance on its FMLA policies?


Opinions:

Majority - Middlebrooks, District Judge

Yes. An employer violates the FMLA by failing to provide an employee with at least fifteen calendar days to furnish medical certification for an unforeseeable leave. The County’s August 4 letter, which gave Cooper only six days to provide certification, was not in compliance with FMLA regulations. The court reasoned that Cooper provided sufficient notice of a potentially FMLA-qualifying condition on July 14. Upon receiving this request, the FMLA required the County to give Cooper written notice of its certification requirement and at least fifteen days to comply, as specified in 29 C.F.R. § 825.305(b). The County's argument that its earlier oral requests were sufficient fails because an employer may only rely on oral notification if it has provided the employee with general written guidance on FMLA policies within the preceding six months, which the County had not done. The court also upheld the award of liquidated damages, finding that while the County may have acted in subjective good faith, its failure to consult the FMLA statute or regulations meant its actions were not objectively reasonable.



Analysis:

This case emphasizes the importance of strict adherence to the FMLA's procedural requirements for employers. It clarifies that an employer's ignorance of the law, even if in good faith, does not excuse non-compliance and can lead to liability for liquidated damages. The decision establishes that for an employer's request for medical certification to be valid, it must provide the statutorily required time for the employee to respond. This holding serves as a strong incentive for employers to develop clear FMLA policies, provide written guidance to employees, and train managers on the specific timelines and notice provisions of the Act.

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