Ena J. Wages v. Stuart Management Corporation
798 F.3d 675
8th Cir.2015Background
- Ena Wages was hired by Stuart Management Corp. (StuartCo) as a full‑time caretaker on November 17, 2008; she worked ~30 hours/week and had an unblemished record.
- In 2009 she had a high‑risk pregnancy; by November her doctor limited her to 20 hours/week and restricted certain duties (no vacuuming/mopping/snow removal). Wages provided StuartCo with the doctor’s note on November 13, 2009.
- StuartCo managers decided to terminate Wages on November 13 and gave her a termination letter on November 16, stating they were unable to accommodate the physician’s restrictions; Wages’s timecard shows she worked on November 16.
- Wages sued under the FMLA (entitlement and retaliation), Title VII, MPLA, and MHRA; the district court granted summary judgment for Wages on the FMLA claims and awarded back pay, prejudgment interest, and liquidated damages.
- On appeal the Eighth Circuit affirmed liability on both FMLA entitlement and retaliation but vacated the damages award and remanded for a jury trial on damages because StuartCo timely demanded a jury and factual disputes (mitigation, bad faith) exist.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Wages an "eligible employee" under the FMLA (12 months)? | Wages argued she had completed 12 months by working through Nov. 16, 2009. | StuartCo argued she was terminated one day before completing 12 months. | Court held Wages satisfied the 12‑month requirement (employment through Nov. 16, 2009). |
| Did Wages give adequate notice to trigger FMLA protection? | Wages contended the doctor’s note (received and given to employer on Nov. 13) sufficiently put StuartCo on notice of pregnancy‑related, reduced hours. | StuartCo argued the note and conduct were insufficient to notify it of FMLA‑qualifying leave. | Court held the doctor’s note and prompt submission were adequate as a matter of law. |
| Was termination retaliatory / causally connected to FMLA leave? | Wages argued termination followed immediately after her request for reduced hours and the termination letter referenced inability to accommodate physician restrictions. | StuartCo argued termination was for inability to perform essential functions due to restrictions, not FMLA exercise. | Court held no reasonable jury could find lack of causal connection; summary judgment for Wages on retaliation affirmed. |
| Were damages properly decided by the district court without a jury? | Wages sought damages and the district court awarded back pay, interest, and liquidated damages without a jury. | StuartCo argued it had a right to a jury on damages and repeatedly requested one; factual issues (mitigation, bad faith) required jury resolution. | Court vacated the damages award and remanded for a jury trial on damages. |
Key Cases Cited
- Rickard v. Swedish Match N. Am., Inc., 773 F.3d 181 (8th Cir.) (standard for reviewing summary judgment).
- Interstate Bakeries Corp. v. OneBeacon Ins. Co., 686 F.3d 539 (8th Cir.) (appellate courts may affirm on any ground in record).
- Smith v. Allen Health Sys., Inc., 302 F.3d 827 (8th Cir.) (elements for FMLA retaliation claim).
- Phillips v. Mathews, 547 F.3d 905 (8th Cir.) (employee need not name FMLA to give notice).
- Twin City Constr. Co. of Fargo v. Turtle Mountain Band of Chippewa Indians, 911 F.2d 137 (8th Cir.) (standard of review for motions to alter/amend judgment).
- Frizzell v. Sw. Motor Freight, 154 F.3d 641 (6th Cir.) (FMLA provides right to jury trial on damages).