Corey Crugher v. John Prelesnik
761 F.3d 610
6th Cir.2014Background
- Crugher is an MDOC employee at Ionia Correctional Facility who has IBS and GAD with recurring flare-ups that require FMLA self-care leave.
- He took intermittent FMLA leave beginning November 2010 and faced time/attendance scrutiny at ICF.
- Crugher was placed on interim ratings tied to his leave and received guidance to provide medical documentation for sick-leave use.
- He was terminated on January 11, 2011, after a second unsatisfactory interim rating process.
- Crugher filed a one-count complaint on April 16, 2013, seeking reinstatement under the FMLA’s self-care provision, relying on Ex parte Young to sue a state official.
- The district court dismissed the action as barred by sovereign immunity or by the FMLA’s 2-year statute of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FMLA limitations period applies to Ex parte Young claims for reinstatement. | Crugher argues Ex parte Young avoids the 2-year limit | Prelesnik and MDOC argue the FMLA two-year period applies | Two-year FMLA period applies to reinstatement claims against state officials. |
| Whether Crugher pleaded willfulness to extend to a 3-year period. | Crugher contends willfulness tolls to 3 years | No willful violation; allegations insufficient | No willfulness pled; 3-year period not applicable. |
| Whether Ex parte Young claims can be pursued against a state official for FMLA reinstatement. | Ex parte Young allows equitable relief against official | FMLA remedies constrain, and sovereign immunity applies to damages | Ex parte Young claim permitted; remedies under FMLA equitable relief available. |
| Whether amendment to plead willfulness would be futile. | Amendment would add willfulness via Prelesnik email | Email unrelated to Crugher’s conduct; futile to amend | Amendment to allege willfulness would be futile. |
Key Cases Cited
- Diaz v. Mich. Dep’t of Corrs., 703 F.3d 956 (6th Cir.2013) (reinstatement and equitable relief under FMLA against state officials not barred by Eleventh Amendment)
- Coleman v. Court of Appeals of Md., 132 S. Ct. 1327 (U.S. 2012) (private damages under FMLA self-care provision barred against states)
- Ex parte Young, 209 U.S. 123 (1908) (allows federal courts to hear suits against state officials for ongoing federal-law violations)
- Hoffman v. Prof'l Med Team, 394 F.3d 414 (6th Cir.2005) (willfulness requires more than a bare allegation; must plead state of mind with plausibility)
- Ricco v. Potter, 377 F.3d 599 (6th Cir.2004) (defines willfulness in FMLA context)
- Mitchell v. Chapman, 343 F.3d 811 (6th Cir.2003) (textual analysis of FMLA employer definition and scope of official-capacity suits)
- Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (1996) (discusses limits of Ex parte Young and abrogation principles)
- Regan v. Time, Inc., 468 U.S. 641 (1984) (principles on constitutional remedies and statutory interpretation)
- Chase Bank USA, N.A. v. City of Cleveland, 695 F.3d 548 (6th Cir.2012) (Supremacy Clause implications for Ex parte Young remedies)
- Va. Office for Prot. and Advocacy v. Stewart, 131 S. Ct. 1632 (2011) (exemplar on Ex parte Young limitations)