Eriksson v. Deer River Healthcare Center (Summary)

TERMINATION OF EMPLOYMENT – FMLA LEAVE

Eriksson v. Deer River Healthcare Ctr., Inc., No. 13-647 (RHK/LIB) (D. Minn. Apr. 18, 2014)

The United States District Court for the District of Minnesota dismissed a physician’s claim against his hospital employer for violation of the Family Medical Leave Act (“FMLA”), holding that the physician was unable to establish the nexus between his termination and his use of FMLA leave because he offered no evidence to link the two other than their temporal proximity (50 days), a proximity the court found insufficient.  Further, the court noted that the hospital proffered a non-discriminatory explanation for the termination – specifically, the physician’s consistent failure to timely complete medical records.  Despite the physician’s allegation that the hospital focused on his delinquent records as a pretext to discriminate against him based on his use of FMLA leave, the court noted that previous to the physician’s request for FMLA leave, the hospital had generated a number of notes and e-mails regarding the physician’s delinquent records, the physician had been involved in numerous conversations with the hospital’s clinic manager regarding his delinquent records, and the clinic had been forced to forego reimbursement for a number of claims due to the physician’s failure to timely document his care.  The court found that the hospital’s escalation of its efforts to address the physician’s documentation failures following his request for FMLA leave did not, in turn, lend to the conclusion that such escalation was the result of that request.