In Chapman v. Brentlinger Enterprises (6th Cir. Nos. 23-3582/3613, 12/13/2024), Chapman alleged various claims including employer interference and retaliation under the Family Medical Leave Act (“FMLA”) following her termination after taking time off to take care of her sister who was dying of cancer. The parties filed cross-motions for summary judgment, portions of which were granted. The Sixth Circuit affirmed in part and reversed in part, and remanded several of the previously dismissed claims to the trial court. Chapman’s FMLA interference claim was remanded for the trial court to determine whether Chapman’s relationship with her sister was in fact an in loco parentis relationship under common law entitled to FMLA protections. Chapman’s FMLA retaliation claim based on her termination for taking and requesting leave was remanded for the trial court to analyze it more fully under the McDonnell-Douglas framework. Finally, Chapman’s FMLA retaliation claim based on her employer’s opposition to her claim for unemployment benefits was remanded for the court to reconsider whether the opposition constituted an adverse employment action. Here, the court held where the employer had opposed the claim on the basis Chapman had “quit”, this could in fact constitute an adverse employment action if the opposition was viewed as dissuading a reasonable worker from exercising their rights for unemployment benefits.
Sixth Ciruit Remands on Various FMLA Claims
