In a recent case, an employee was terminated while on family medical leave following the birth of a child. The employer admitted that she had shown causation through use of temporal proximity, she was terminated while on the leave, but claimed a legitimate, non-discriminatory reason for the termination of her position. She was terminated as part of a four-person reduction in force (RIF), eliminating her business unit. Because there was no shown decline in business, the Court suggested that this raises a question of fact regarding the genuineness of the RIF. Moreover, there were a number of job openings at the time that she was terminated, and employees were, in fact, hired thereafter. Further, they made no real attempt to place her in another position to which she might be qualified. This matter will not go to trial, as factual issues remain. Hillins v. Marketing Architects, Inc. (D.C. Minn. 2011).