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Rodney Jonesv.Gulf Coast Health Care Of Delaware, Llc

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.16-11142
DecidedApril 19, 2017
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CivilEmployment LawEmployment DiscriminationStatutory InterpretationSummary JudgmentReversalRemand
Case Summary

Rodney Jones sued his former nursing-facility employer under the Family and Medical Leave Act after taking leave for shoulder surgery and later being suspended and fired. The district court granted summary judgment to the employer on both his interference and retaliation claims. The Eleventh Circuit affirmed the judgment on interference but reversed on retaliation. The court held that an employee pursuing FMLA retaliation need not show that the employer’s stated reason for the adverse action was false at the prima facie stage; the employee must present evidence from which a jury could find a causal connection between protected leave and the action. Because the circuit had not previously addressed that issue in a published decision, the court clarified the governing framework and held that Jones presented sufficient evidence to proceed. The case was remanded for further proceedings on retaliation.

Opinion

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Rodney Jones V. Gulf Coast Health Care Of Delaware, Llc — The Atlanta Gleaner