Ahmann v. Blattner Holding Company, LLC, 0:23-cv-02620

Kimberly Ahmann worked for Blattner Holding Company for about three years and initially received positive performance feedback.
In early 2021, Ahmann's health deteriorated, resulting in her taking medical leave, including a hospital stay.
Ahmann contends she was entitled to leave under the FMLA, but Blattner asserts it never received the necessary FMLA paperwork and deemed her absences unprotected.
During the period of worsening health, Ahmann’s job performance was questioned and she received escalating disciplinary warnings, eventually culminating in her termination in June 2022.
Ahmann sued Blattner for FMLA interference and retaliation; Blattner moved for summary judgment, arguing insufficient FMLA eligibility and non-pretextual reasons for termination.
The court denied Blattner’s motion, citing genuine disputes of material fact regarding FMLA eligibility, employer knowledge, interference, and the reason for Ahmann’s dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
FMLA Eligibility & Completed Documentation	Ahmann submitted FMLA paperwork and satisfied requirements for leave	Blattner never received completed FMLA paperwork, so Ahmann was not eligible	Fact dispute; summary judgment not granted
Medical Necessity for Intermittent Leave	Medical providers indicated ongoing need for FMLA leave during recovery	Medical evidence did not support necessity for intermittent leave	Fact dispute; summary judgment not granted
Employer Knowledge of FMLA Need	Blattner was adequately informed about Ahmann's health issues and need for FMLA leave	Only knew of Ahmann being sick, not an FMLA-qualifying reason; thus, no duty was triggered	Fact dispute; summary judgment not granted
Causation/Pretext in Retaliation	Termination closely followed FMLA-related activity; reasons for firing were pretextual	Termination was due to job performance, not FMLA-related activity	Fact dispute; summary judgment not granted

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard – material fact and genuine dispute)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (standards for reasonable inferences on summary judgment)
Phillips v. Mathews, 547 F.3d 905 (burden shifting for FMLA retaliation and fact questions re: employer notice)
Smith v. AS America, Inc., 829 F.3d 616 (elements for FMLA interference claim)
Brown v. Diversified Distrib. Sys., LLC, 801 F.3d 901 (applying McDonnell Douglas framework to FMLA retaliation)
Thompson v. Kanabec County, 958 F.3d 698 (private right of action under FMLA and elements for interference/retaliation)