Hearst v. Progressive Foam Technologies, Inc., 641 F.3d 276

Hearst worked for Progressive Foam Technologies (PFT) from March 15, 2006, to May 1, 2007.
In December 2006 Hearst was injured in a non-work-related accident, requiring medical leave starting January 3, 2007.
PFT informed Hearst he was eligible for FMLA leave and that the leave would count against his FMLA entitlement.
Multiple physicians extended Hearst’s return-to-work dates, with final estimates pushing recovery into May 2007.
PFT extended the FMLA leave in March 2007 and later fired Hearst on May 1, 2007 for job abandonment after he failed to report.
Hearst alleged FMLA interference and retaliation, and COBRA notice issues; district court granted summary judgment for PFT.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did firing interfere with FMLA leave?	Hearst contends pre-May 1 timing impaired FMLA rights.	PFT argues no interference because either already exhausted or not prejudicial.	No material prejudice; summary judgment affirmed on interference.
Was there retaliation claim adequately supported?	Hearst claims firing for exercising FMLA rights.	PFT maintains reason was policy noncompliance, not retaliation.	Summary judgment proper; no pretext shown.
Did PFT mail COBRA notice properly?	Hearst did not receive notice; method failed.	Evidence shows notice mailed by reasonable method to reach Hearst.	Yes, notice reasonably calculated to reach; summary judgment for PFT.

Crotty v. Dakotacare Admin. Servs., Inc., 455 F.3d 828 (8th Cir. 2006) (good-faith, reasonably calculated notice suffices under COBRA)
Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (Sup. Ct. 2002) (prejudice required under FMLA; counting without prejudice inconsistent with statute)
Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct. 1986) (summary-judgment burden; evidence must show genuine dispute)
Brandt v. Davis, 191 F.3d 887 (8th Cir. 1999) (standard for reviewing district court's summary-judgment grant)