Heather Chandler, an employee of Specialty Tires of America in Tennessee, took an overdose of pills one weekend and was rushed to the hospital in a semi-conscious state. Chandler remained in the hospital for several days and received psychiatric treatment. During that time, she called her employer to explain the situation and requested time off for medical treatment. Her employer placed her on paid leave. When her immediate supervisor learned of the situation, he decided to terminate her employment, believing that he could not longer trust her to handle her duties because she was irresponsible in taking the pills.
Chandler received a termination letter five days after her overdose. When she returned to work to retrieve her possessions, she requested that she be returned to her job or to a similar position, but her supervisor refused her request. Chandler sued. The jury found in her favor, awarding her $18,326.01 in compensatory damages, which the court increased to $83,972.50 to include liquidated damages, attorneys'' fees and costs.
On appeal to the Sixth Circuit, the issue before the court was whether the jury could have reasonably found that Chandler was fired for taking leave rather than for ingesting an overdose of drugs, or even for having been diagnosed with depression. Specialty Tires argued that no legal basis supported the jury''s verdict because Chandler''s act of overdosing was not protected by the FMLA. Chandler argued that there was no distinction between firing her for overdosing or for taking medical leave to treat her underlying depression.
The Sixth Circuit disagreed with Specialty Tires. It stated that "[a]lthough the factual scenarios that give rise to an FMLA or ADA cause of action may often coincide, the legal entitlements that flow from these facts will differ." The Court held that because the employer knew that Chandler was on medical leave while she was hospitalized for the suicide attempt and fired her shortly after learning of her hospitalization, the proximity in time between taking leave and being terminated suggested a causal link. "[I]t was not unreasonable for the jury to infer from the evidence that Chandler was fired for taking leave," the court concluded, denying Specialty Tires'' motion for a new trial.
Laura L. Hoppenstein is an associate of Kollman & Saucier, P.A. in Baltimore, Maryland. She received her undergraduate degree from the University of Maryland (1993), and her law degree from the University of Baltimore School of Law (2000). Laura writes monthly articles for Bender´s Labor & Employment Bulletin and has lectured on the topics of FMLA and Maryland Wage and Hour laws. At the University of Baltimore School of Law, she was a member of the Labor Law Moot Court Team, President of the Moot Court Board, a Teaching Assistant for the Legal Writing program, and a member of the Intellectual Property Law journal. She was also the recipient of the National Association of Women Lawyers'' award for her service to the University of Baltimore. Laura is a member of the Maryland and District of Columbia bars.
You can reach Laura at Laura@kollmanlaw.com.
