Patel v. Saint Vincent Health Ctr. (Summary)

FMLA

Patel v. Saint Vincent Health Ctr., No. 12-0298 ERIE (W.D. Pa. Aug. 28, 2013)

During the second year of her residency program, a resident was placed on notice of her academic deficiencies.  Subsequently, the resident requested FMLA leave in order to treat a heart condition.  This leave was granted and the resident acknowledged that she would be terminated if she did not return to work when the leave expired.  The resident requested an extension to her leave, which the residency program said would be granted if her treating physician would provide the program with an order for the extension.  The resident failed to obtain the order from her treating physician and she was terminated due to her unauthorized leave of absence.  The resident sued the residency program alleging that her termination violated the FMLA and requested that the court order the residency program to reinstate her.  The United States District Court for the Western District of Pennsylvania denied the resident’s request.  The court held that the resident failed to establish interference with her FMLA rights because she did not properly request, and was not entitled to, the extended leave.