UPS did not violate the Family and Medical Leave Act when it denied leave to a worker who did not submit proper documentation, the 11th U.S. Circuit Court of Appeals said Oct. 17, upholding a lower court’s ruling.
The plaintiff failed to not submit required certification documentation to UPS or its benefits partner, Aetna Life Insurance Company, the 11th Circuit said. Instead, he submitted a one-page document that “did not list a date of onset, did not include any information about the nature of his illness, and noted only that Walker could not perform heavy lifting, carrying, pushing, [or] pulling until December 6, 2016.”
Beyond that, nothing about his arguments — regarding the denial of his leave — indicated he was prejudiced by UPS’ actions, the court said.
Under the FMLA, eligible employees are entitled to 12 weeks of leave over a 12-month period. This leave is for “serious health conditions,” including mental or physical illness, impairment or injury, where healing takes place either in a medical facility or involves continual treatment from a health care provider. Employees may also use the leave after the birth or adoption of a child or to care for another immediate family member.
In order to be legitimately considered for personal medical FMLA leave, workers must submit a number of materials for medical certification. This includes the name, address and phone number of the health care provider, and information on their specialty and practice. This should also include the approximate date on which the condition started, its probable duration, and a more clinical description of the employee’s health status — symptoms, diagnoses, hospitalizations and doctors' visits, whether any medication has been prescribed, treatment referrals and the like, the court said, citing federal regulations. Ultimately, the worker must show that they cannot fulfill their given role at work while the health condition persists.
“We are pleased with the court’s decision,” UPS Director of Media Relations Matthew O’Connor said to HR Dive.
“One of UPS’s core values is that people should be respected and protected in the workplace,” O’Connor continued. “The company does not tolerate comments or actions that are considered discrimination or retaliation, and offers several ways to report and resolve issues with confidence.”