Chappell v. Bilco Co.
675 F.3d 1110
| 8th Cir. | 2012Background
- Chappell, African American, employed by Bilco from 2002 until termination on August 10, 2007.
- Bilco amended its attendance policy in Sep 2006, tying absences to a points system and disciplinary steps.
- Chappell had prior 2005 race-discrimination and FMLA claims; July 2006 settlement occurred.
- Oct 2–3, 2006: Chappell's mother had hip surgery; he left messages but did not speak with a supervisor; three-point assessments per day led to seven-point total and a three-day suspension.
- Chappell sought FMLA leave prior to surgery; certification documented caregiving; later certifications covered transportation and chronic conditions.
- July 2007: absences claimed as FMLA leave; Bilco required documentation; Chappell failed to provide docs; he was suspended and later faced termination after an August 2, 2007 incident.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bilco interfered with FMLA rights in Oct 2006 incidents | Chappell was penalized under attendance policy for not speaking to a supervisor. | Points were for policy violation, not for exercising FMLA rights. | No interference; actions tied to attendance policy violations. |
| Whether Bilco interfered with FMLA rights in July 2007 absences | Bilco denied FMLA leave for caregiving during mother's illness. | Chappell failed to provide timely medical certification; no adequate notice of need for leave. | No interference; lack of adequate/timely notice under FMLA. |
| Whether Bilco's termination was retaliation for FMLA rights or merely for attendance violations | Termination was pretext for retaliation for exercising FMLA rights. | Termination due to attendance violations; evidence of pretext insufficient. | No retaliation; Bilco's justification supported; no pretext shown. |
| Whether Chappell established race discrimination under § 1981 | Comparators treated more favorably; evidence of racial animus. | No sufficient evidence of similarly situated comparators or causal link; timing insufficient. | Summary judgment for Bilco; no substantially similar comparators or causal link shown. |
Key Cases Cited
- Wierman v. Casey's Gen. Stores, 638 F.3d 984 (8th Cir. 2011) (discrimination summary judgment standard; pretrial tool)
- Estrada v. Cypress Semiconductor, Inc., 616 F.3d 866 (8th Cir. 2010) (FMLA interference not strict liability; requires causal analysis)
- Woods v. DaimlerChrysler Corp., 409 F.3d 984 (8th Cir. 2005) (adequate notice and leave requirements under FMLA)
- Thorson v. Gemini, Inc., 205 F.3d 370 (8th Cir. 2000) (FMLA notice requirements and leave certification)
- Rynders v. Williams, 650 F.3d 1188 (8th Cir. 2011) (adequate/timely notice for FMLA leave)
- Boner v. Bd. of Comm'rs, 674 F.2d 697 (8th Cir. 1982) (similarly situated comparators standard in discrimination cases)
- Rodgers v. U.S. Bank, N.A., 417 F.3d 845 (8th Cir. 2005) (comparators and similarly situated analysis in discrimination claims)
- Sprenger v. Fed. Home Loan Bank of Des Moines, 253 F.3d 1106 (8th Cir. 2001) (McDonnell Douglas framework for retaliation/discrimination)
- Sims v. Sauer-Sundstrand Co., 130 F.3d 341 (8th Cir. 1997) (causation and timing in discrimination cases)
- Sims v. Sauer-Sundstrand Co., 130 F.3d 341 (8th Cir. 1997) (causation and timing in discrimination cases)
- Lovland v. Employers Mutual Casualty Co., 674 F.3d 806 (8th Cir. 2012) (reaffirmation of FMLA retaliation/interference standards)