Campbell v. Jefferson University Physicians
22 F. Supp. 3d 478
E.D. Pa.2014Background
- Campbell sues JUP under the FMLA; JUP moves for summary judgment on Campbell's claim.
- Plaintiff alleges JUP interfered with, restrained, discriminated against, and denied FMLA rights.
- Defendant argues Campbell's claims rely on a false assertion by the third-party administrator that she was terminated.
- Courtly analysis focuses on FMLA interference vs retaliation and prejudice required by the statute.
- Record shows Campbell was absent and there was a disputed termination, but the court finds no prejudice from alleged FMLA violations.
- Court grants summary judgment for JUP, terminating the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Campbell proves FMLA retaliation. | Campbell | JUP | Waived; no address of retaliation evidence. |
| Whether Campbell proves FMLA interference with prejudice. | Campbell | JUP | No prejudice shown; entitlement not denied meaningfully. |
| Whether an FMLA recertification notice issue mattered. | Campbell | JUP | Not controlling; no harm shown given later termination. |
Key Cases Cited
- Callison v. City of Philadelphia, 430 F.3d 117 (3d Cir. 2005) (Interference standard; prejudice requirement limits remedy)
- Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (U.S. Supreme Court 2002) (Remedy tailored to harm; no relief without prejudice)
- Peter v. Lincoln Technical Institute, Inc., 255 F.Supp.2d 417 (E.D. Pa. 2002) (Notice and certification requirements; interference nexus)
- Conoshenti v. P.S.E.&G., 364 F.3d 135 (3d Cir. 2004) (Prejudice showing required for FMLA interference)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (Weighing credibility and evidence in summary judgment)