On October 11, 2024, in the matter of Ephriam Rodriquez v. Southeastern Pennsylvania Transportation Authority (“SEPTA”), the Third Circuit Court of Appeals addressed the legal standards for establishing a “serious health condition” under the Family and Medical Leave Act (“FMLA”). This decision highlights what constitutes a “serious health condition” under the FMLA, and the standards that should be applied in assessing such claims.
Background Ephriam Rodriquez, a bus operator for SEPTA, was terminated from his position after accruing too many negative attendance points, as outlined by his union’s Collective Bargaining Agreement with SEPTA. It was undisputed that his final absence, which contributed to his termination, was due to a migraine headache, an ailment for which he later sought FMLA leave. Despite Rodriquez’s attempt to secure FMLA leave by visiting a physician and submitting the necessary paperwork, SEPTA proceeded with a formal hearing that ultimately upheld his termination.
Rodriquez took legal action against SEPTA, alleging retaliation and interference under the FMLA. While a jury found in favor of Rodriquez on the interference claim, awarding him $20,000 in economic damages, the District Court later granted SEPTA’s motion for judgment as a matter of law, overturning the jury’s verdict. The Decision The Third Circuit’s review focused on whether the district court erred in its judgment as a matter of law regarding the FMLA interference clai.
