Montone v. Schuylkill Health Sys. (Summary)

CIVIL RIGHTS

Montone v. Schuylkill Health Sys.
No. 3:11-CV-2252 (M.D. Pa. July 3, 2014)

fulltextThe U.S. District Court for the Middle District of Pennsylvania denied a hospital’s motion for summary judgment against a former employee’s Family and Medical Leave Act of 1993 (“FMLA”) retaliation claim. The employee filed her lawsuit after she was fired from her position as Director of Patient Accounts.

The Employee testified that her supervisor, the Vice President of Finance, prohibited her from taking time off except for an FMLA absence. The Employee was therefore forced to file for FMLA leave in order to cope with a new diagnosis of multiple sclerosis which caused her to suffer exhaustion, memory loss, and painful headaches. The Hospital contended that the Employee was actually discharged because of her failure to manage the billing and collection of patient accounts, causing the hospital to experience significant revenue shortfalls.

The court cited several factors in support of its decision to let the claim proceed to trial. First, the court explained that the timing of events was sufficient on its own to create an inference of FMLA retaliation. The Employee had taken FMLA leave on consecutive business days: a Friday and a Monday. The Hospital terminated her as soon as she returned on Tuesday. In addition, the court noted that the Employee had never been subject to any disciplinary actions or to any poor performance reviews during her three decade long tenure with the Hospital. Finally, the court highlighted the fact that the Vice President of Finance prohibited the employee from taking any time off absent a request for FMLA. This led the court to conclude that the hospital’s reasons for terminating the employee could have been a pretext for its retaliation against her for exercising her FMLA rights.