Graziadio v. Culinary Institute of America

What the court decided

A payroll administrator took FMLA leave to care for one son with newly diagnosed diabetes and another with a broken leg. Her employer made vague demands for "paperwork," ignored her repeated requests to say what it needed, refused to discuss the matter except at a meeting it never scheduled, and then fired her for abandoning her job. The court held that a jury could find the employer interfered with her FMLA rights and retaliated against her: under the Labor Department's rules, which the court applied, an employer "must give notice of a requirement for certification each time a certification is required," and it must answer employees' questions about their obligations. It also held that a human resources director can be personally liable under the FMLA, and it rejected her ADA associational claim because she was fired for taking leave, not because of assumptions about her son's condition.

Who won

Split. The Second Circuit vacated summary judgment on her FMLA claims and sent them back, and affirmed dismissal of her ADA claim.

Why it matters for workers with a medical condition

The FMLA, not the ADA, is what protects time off to care for a family member. If your employer says your paperwork is not enough, it has to tell you what it needs and give you a fair chance to provide it.

Key passage: 817 F.3d at 422–33.

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This page summarizes the decision in plain language.