Germanowski v. Harris, 854 F.3d 68

Germanowski was First Assistant Register at the Berkshire Middle District Registry of Deeds and worked with Patricia Harris, who became her supervisor in Jan 2013; their relationship soured and Germanowski was terminated in Feb 2015.
Over 2014–2015 Germanowski experienced anxiety and related symptoms, sought medical care, informed Harris of visits and diagnosis, and took a leave in Oct 2014 with Harris's acquiescence.
Between June 2014 and Jan 2015 Harris pressured Germanowski for political contributions, reassigned duties, excluded her from meetings, made accusatory comments, and twice told Germanowski not to come to work.
On Feb 3, 2015 Germanowski emailed that she would be out sick for the week and was scheduled to see her doctor; she saw her psychiatrist on Feb 5 who recommended leave (letter not alleged to have been provided to employer).
On Feb 6, 2015 Harris (through court officer and written notice) terminated Germanowski. Germanowski sued under the FMLA and state law; the district court dismissed FMLA claims against the Commonwealth on Eleventh Amendment grounds and dismissed the remaining FMLA retaliation claim for failure to plausibly allege causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complaint plausibly alleges FMLA retaliation (causal link between protected activity and termination)	Germanowski contends her Feb 3 email notifying she would be out to see a doctor was FMLA-protected conduct and proximate in time to termination, supporting causal inference	Harris argues the email was a generic "sick" notice (insufficient to invoke FMLA) and, even if FMLA notice, termination was set in motion earlier for non-FMLA reasons	Court affirmed dismissal: complaint fails to plausibly allege causation—termination was likely initiated before Feb 3 and prior conduct undermines inference of retaliatory motive

Ashcroft v. Iqbal, 556 U.S. 662 (addresses plausibility standard for pleadings)
Carrero-Ojeda v. Autoridad de Energía Eléctrica, 755 F.3d 711 (1st Cir. 2014) (pleading standards on Rule 12(b)(6) review)
Colburn v. Parker Hannifin/Nichols Portland Div., 429 F.3d 325 (1st Cir. 2005) (FMLA reinstatement and interference/retaliation framework)
Rodríguez-Reyes v. Molina-Rodríguez, 711 F.3d 49 (1st Cir. 2013) (prima facie elements inform plausibility inquiry)
Ameen v. Amphenol Printed Circuits, Inc., 777 F.3d 63 (1st Cir. 2015) (retaliator must have known of protected activity for causation)