Felicia Holton v. First Coast Service Options, Inc.
703 F. App'x 917
| 11th Cir. | 2017Background
- Holton, a Medicare-claims processor, took FMLA leave for back pain and sought to return on March 27, 2013 with a chiropractor’s note limiting her to 4-hour workdays for two weeks.
- First Coast told Holton a chiropractor’s note was insufficient (no physician on staff) and that she must either return full-time, provide a physician’s note, or apply for other posted positions.
- Holton contacted the DOL Wage and Hour Division, which communicated with First Coast; First Coast subsequently sent a letter warning that failure to report could be treated as resignation.
- Holton did not return to work and was terminated effective April 9, 2013; she sued claiming ADA failure to accommodate and FMLA interference and retaliation.
- The district court granted summary judgment to First Coast; Holton appealed. The Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA failure to accommodate — whether Holton was disabled | Holton argued her back impairment substantially limited major life activities (walking, bending, sitting) based on chiropractor’s note | First Coast argued the chiropractor’s two-sentence note did not establish a disability under the ADA | Court held Holton failed to prove disability; summary judgment affirmed |
| FMLA interference — whether requested reduced schedule is protected | Holton argued First Coast prevented reinstatement after FMLA leave by refusing modified schedule | First Coast argued FMLA guarantees return to same or equivalent position, not a right to a reduced schedule; it offered full-time reinstatement or other options | Court held FMLA did not protect the modified-schedule request; no interference |
| FMLA retaliation — whether termination was retaliatory for contacting DOL | Holton argued temporal proximity between DOL contact and termination showed retaliation | First Coast proffered legitimate, non-discriminatory reason: termination for failure to report to work under company policy | Court held Holton failed to show pretext; termination lawful and summary judgment affirmed |
| Procedural: treatment of pro se pleadings on summary judgment | Holton suggested liberal construction should salvage claims | First Coast noted pro se status does not permit wholesale re-drafting; must produce evidence to survive summary judgment | Court applied liberal construction but required evidentiary support; pro se status did not alter summary-judgment standards |
Key Cases Cited
- Vessels v. Atlanta Indep. Sch. Sys., 408 F.3d 763 (11th Cir.) (standard for reviewing summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary-judgment burden-shifting principles)
- Anderson v. Liberty Lobby, 477 U.S. 242 (evidentiary standard: more than a scintilla required)
- Mazzeo v. Color Resolutions Int’l, LLC, 746 F.3d 1264 (physician affidavit may suffice to show ADA disability when it details limitations)
- O’Connor v. PCA Family Health Plan, Inc., 200 F.3d 1349 (FMLA interference cause of action)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (burden-shifting framework for retaliation claims)