After more than 20 years working for the employer, Leigh took leave under the federal Family and Medical Leave Act (FMLA) due to mental health concerns. When she returned to work, the employer said it was terminating her based on unsatisfactory job performance discovered while she was on leave. Leigh sued, arguing that the employer terminated her in retaliation for taking FMLA leave. Sky Transport Solutions helps employers understand this important case and its implications for FMLA compliance.
The Critical Admission
In court, however, Leigh admitted that she was able to do the essential functions of her job at all relevant times. Both she and her doctor agreed that she was never unable to perform the functions of her position, so she wasn't incapacitated under the FMLA. This comment doomed Leigh's argument that she was entitled to FMLA leave.
FMLA Eligibility Requirements
Under the FMLA, employees are entitled to leave for a serious health condition that makes them unable to perform the essential functions of their position. In this case, Leigh's admission that she was always able to perform her job functions meant she did not meet the FMLA's eligibility requirements for leave.
FMLA Serious Health Condition Requirements
For FMLA leave to be valid, an employee must have a serious health condition that:
- Makes the employee unable to perform the essential functions of their position, or
- Requires continuing treatment by a health care provider
In Leigh's case, both she and her doctor confirmed she was never unable to perform her job functions, which meant she did not have a qualifying serious health condition under the FMLA.
The Estoppel Argument
Under the FMLA, even when employees aren't entitled to leave, if issues like Leigh's pop up, employees could argue that an employer "represented" (i.e., indicated) that they were eligible, had reason to believe they could rely on that representation, and relied on that representation to their detriment (i.e., they get disciplined for taking FMLA leave).
In Leigh's situation, the court found that she didn't show that she detrimentally relied on the employer's representation that she was eligible for leave. Instead, Leigh testified that she would have taken the full amount of leave regardless of the employer's approval.
Elements of Estoppel Argument:
- Employer represented (indicated) that the employee was eligible for FMLA leave
- Employee had reason to believe they could rely on that representation
- Employee relied on that representation to their detriment
In this case, Leigh failed to show detrimental reliance because she testified she would have taken the leave regardless of the employer's approval.
Court Ruling
Because Leigh didn't have an FMLA serious health condition and didn't rely on the employer's representation, the court ruled in favor of the employer, resolving the case and preventing a jury trial.
Case Citation:
Holland v. Texas Christian University, Fifth Circuit Court of Appeals, No. 25-10567, September 8, 2025
Key Takeaway from Sky Transport Solutions
Even if a certification supports an employee's leave, if the employee then admits that they aren't incapacitated, their argument that they had FMLA rights, and the employer violated those rights fails. Sky Transport Solutions recommends that employers carefully review FMLA certifications and ensure employees meet the eligibility requirements, particularly the requirement that they be unable to perform essential job functions.
Lessons for Employers
This case provides important guidance for employers managing FMLA leave requests:
- Verify Eligibility: Ensure employees requesting FMLA leave actually meet the eligibility requirements, including being unable to perform essential job functions
- Document Carefully: Maintain clear documentation of FMLA certifications and any inconsistencies
- Consistent Application: Apply FMLA policies consistently and in accordance with legal requirements
- Review Certifications: Carefully review medical certifications to ensure they support FMLA eligibility
- Legal Guidance: Consult with legal counsel when dealing with complex FMLA situations
How Sky Transport Solutions Can Help
At Sky Transport Solutions, we understand that FMLA compliance is complex and requires careful attention to detail. Our team can help employers:
- Understand FMLA eligibility requirements and serious health condition definitions
- Develop policies and procedures for handling FMLA leave requests
- Review and evaluate FMLA certifications for completeness and accuracy
- Train managers and HR staff on FMLA compliance requirements
- Document FMLA leave requests and certifications properly
- Navigate complex FMLA situations and estoppel arguments
- Ensure consistent application of FMLA policies across the organization
FMLA compliance requires careful attention to both the letter and spirit of the law. Contact Sky Transport Solutions today to ensure your organization's FMLA policies and practices are compliant and protect your business from potential litigation.
Sky Transport Solutions provides comprehensive compliance support for trucking companies nationwide. Stay informed about critical regulatory changes that impact your business operations.