Plaintiff Faron Snow sued defendant Hutchens Industries, Inc. in the United States District Court for the Western District of Missouri, raising claims of FMLA interference and retaliation. Before the court is Defendant Hutchens Industries’ motion for summary judgment.
Statement of Undisputed Facts
Hutchens Industries designs and manufactures trailer suspensions and metal products. Snow worked as an hourly employee at Hutchens’ Mansfield plant from March 2014 to April 2023. On February 20, 2023, Snow requested FMLA leave until March 20, which was approved. Snow later extended his leave to April 3, 2023, with proper documentation. Hutchens maintained a three-day “no call no show” policy, whereby employees absent for three consecutive working days without notification were considered to have voluntarily quit.
Snow visited Hutchens’ HR office on April 5, 2023, after obtaining a new doctor’s note extending his leave to April 17. A key dispute exists regarding whether Snow provided this note to HR Director Dobson during their meeting. Snow did not work or contact Hutchens on April 6, 10, and 11, leading to his termination on April 11, 2023.
Legal Analysis
FMLA Claims: The court analyzed both FMLA interference and retaliation claims. While employees on FMLA leave have no greater protection against termination for unrelated reasons, the court found a genuine dispute of material fact regarding whether Snow submitted the April 5 doctor’s note. The court determined that Snow’s evidence, including the dated doctor’s note and his testimony, could lead a reasonable jury to conclude he had properly extended his FMLA leave.
Summary Judgment Standard: The court emphasized that its role was not to weigh evidence but to determine whether genuine issues existed for trial. The court found that Snow’s evidence, beyond his self-serving affidavit, created a triable issue regarding whether his absences were excused under FMLA.
The court denied Hutchens’ motion for summary judgment, finding that a jury must determine whether Snow’s absences were excused under FMLA.
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