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Theresa Spangler v. Federal Home Loan Bank of Des Moines

Court of Appeals for the Eighth Circuit
278 F.3d 847 (2002)
ELI5:

Rule of Law:

An employee provides sufficient notice to trigger an employer's obligations under the Family and Medical Leave Act (FMLA) when they provide enough information to put the employer on notice that the absence may be for an FMLA-qualifying reason. Once such notice is given, the burden shifts to the employer to inquire further to determine if the leave is in fact FMLA-qualifying.


Facts:

  • Theresa Spangler began working for the Federal Home Loan Bank of Des Moines (the Bank) in 1982 and was diagnosed with dysthymia, a form of depression, in 1993.
  • Spangler took medical leaves of absence for her depression in 1993 and 1997, and she informed her supervisors about her condition.
  • Throughout her employment, Spangler had a persistent pattern of absenteeism and tardiness, for which she received counseling, warnings, and was placed on probation multiple times.
  • In July 1997, a member bank complained that Spangler's absenteeism was interfering with its business operations.
  • On September 16, 1998, while on probation for absenteeism, Spangler notified the Bank that she would not be at work because of 'depression again.'
  • On September 17, 1998, after Spangler did not arrive at work or call with an explanation, her manager terminated her employment.

Procedural Posture:

  • Theresa Spangler filed suit against the Federal Home Loan Bank of Des Moines in the United States District Court, alleging violations of the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA).
  • The Bank moved for summary judgment on both of Spangler's claims.
  • The district court (the trial court) granted the Bank's motion for summary judgment, dismissing both the ADA and FMLA claims.
  • Spangler (appellant) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Eighth Circuit.

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Issue:

Does an employee provide sufficient notice to trigger an employer's obligations under the Family and Medical Leave Act (FMLA) by informing the employer that an absence is due to 'depression again,' when the employer is already aware of the employee's history of depression?


Opinions:

Majority - Riley, Circuit Judge.

Yes, an employee's statement that an absence is due to 'depression again,' coupled with the employer's prior knowledge of the employee's condition, is sufficient to create a genuine issue of material fact as to whether the employer was on notice of the employee's need for FMLA leave. An employee is not required to specifically invoke the FMLA by name. Once an employee provides enough information to suggest the leave may be FMLA-qualifying, the duty shifts to the employer to inquire further and determine the nature of the leave, such as by requesting medical certification. Here, the Bank was aware of Spangler's history with depression, and her explicit reference to 'depression again' could be interpreted by a reasonable jury as a valid request for FMLA leave, precluding summary judgment. The court distinguished this from cases where an employee merely calls in 'sick,' as Spangler provided a specific, known, and potentially serious health condition as the reason for her absence.



Analysis:

This decision clarifies the relatively low threshold for an employee to provide sufficient notice for FMLA leave, especially in cases involving unforeseeable leave for a chronic condition. It firmly places the burden of inquiry on the employer once it has a reasonable basis to believe an absence might be covered by the FMLA. The case also draws a critical distinction between the protections of the FMLA and the ADA: while the ADA protects individuals who can perform the essential functions of a job, the FMLA is designed to provide job security for employees who are temporarily unable to perform their job functions due to a serious health condition. This ruling reinforces that an employee's poor attendance record, while relevant to an ADA claim, does not automatically defeat an FMLA claim if a specific absence is properly noticed as FMLA-qualifying.

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