Coleman v. Maryland Court of Appeals: Important Supreme Court Decision Regarding the Family and Medical Leave Act
The Family and Medical Leave Act’s self-care provision permits an employee to take leave if there is a serious health condition that makes the employee unable to perform the functions of the position of such employee. The plaintiff, Daniel Coleman, worked at the Court of Appeals of Maryland when he requested leave under the self-care provision of the Family and Medical Leave Act (FMLA). Thereafter, he was told that he would be terminated if he did not resign. Coleman believed that the termination was retaliation for his taking leave under the FMLA, and he filed suit.
The issue before the Supreme Court was whether Congress abrogated the state’s sovereign immunity when it passed the self-care provision of the Family and Medical Leave Act. The following are notable aspects of this case:
- Coleman argued that Maryland was not immune from suits stemming from the self-care provision of the FMLA. He also argued that this provision should be treated the same way other gender nondiscrimination laws operate, since the self-care provision is aimed at stopping discrimination against female employees who take leave for pregnancy. For those laws, Congress abrogated state immunity from lawsuits.
- Maryland argued the self-care provision relates to discrimination based on medical conditions and serious health problems rather than gender, and as such, do not permit private causes of action. Maryland also points out that employees can still seek injunctive relief and the Department of Labor can bring an action against a state for violating the self-care provision.
- The Supreme Court disagreed with Coleman, holding that Congress did not abrogate the state’s immunity and leave it open to lawsuits with regard to the self-care provision of the Family and Medical Leave Act.
- The family care provisions of the FMLA do abrogate the state’s immunity from suit, but the self-care provisions do not.
- In a close decision, the U.S. Supreme Court sided with the 4th Circuit Court of Appeals, noting that Congress did not abrogate the state’s immunity to suit as it pertains to the self-care provision of the FMLA.
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