In Coleman v. Court of Appeals of Maryland, (No. 10-1016, Mar. 20, 2012), the Supreme Court, in a 5-4 vote, held that state employees cannot sue states under the “self-care” provision of the Family and Medical Leave Act (FMLA).
The case involved Daniel Coleman, an individual employed by the Maryland Court of Appeals. Coleman requested FMLA leave for a serious medical condition, and the Court of Appeals terminated him. Coleman claimed the termination was in violation of the FMLA, which entitles an employee to take up to 12 weeks of unpaid leave per year for the employee’s own serious health condition when the condition interferes with the employee’s ability to perform at work, and brought suit. Maryland argued that Coleman’s claim was barred by sovereign immunity and should be dismissed. According to Maryland, the self-care provision of the FMLA was passed pursuant to the Commerce Clause of the U.S. Constitution, which cannot be used to bypass the state’s sovereign immunity. In order to avoid the state’s sovereign immunity and allow the lawsuit, it had to be shown that the self-care provision of the FMLA remedies a pattern of gender-based discrimination in states’ sick leave policies.
The Federal District Court, the Court of Appeals for the Fourth Circuit, and ultimately the Supreme Court ruled in favor of Maryland. The Court held that Congress lacked authority to abrogate states’ sovereign immunity because the FMLA self-care provision was not tailored to remedy or prevent discriminatory conduct violating the Fourteenth Amendment. The Court determined that the FMLA provision entitling employees to take leave for their own serious medical conditions is completely different than the provisions relating to family-care leave, which are protected. No basis existed to conclude that state employers had previously discriminated against employees on the basis of sex in regard to sick leave, and thus there was no reason to hold state employers liable for damages under this provision of the Family and Medical Leave Act.
The Court’s decision potentially leaves state employees without legal recourse in the event they are denied FMLA leave for self-care or terminated because of the need for leave. Ultimately, it was suggested that an employee can still seek injunctive relief to stop an employer from violating the FMLA, even though the employee can not recover monetary damages.
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