John Vannoy v. Federal Reserve Bank
827 F.3d 296
| 4th Cir. | 2016Background
- Vannoy worked for the Federal Reserve Bank of Richmond (FRBR) from 1994 until termination on Dec. 21, 2010; by 2010 he had attendance/performance problems and a history of depression.
- In November 2010 Vannoy was hospitalized for depression; he applied for short-term disability which served as an FMLA leave request from Nov. 10 to Dec. 10 and FRBR approved leave through Dec. 10.
- FRBR (via its Medical Director) claims to have emailed an individualized FMLA "rights and responsibilities" notice on Nov. 16; the only notice in the record omitted any statement about job-restoration rights, and Vannoy disputes receipt.
- Afraid of losing his job, Vannoy returned to work early (Nov. 15–16); later misconduct/attendance issues (including an unauthorized absence on a Baltimore assignment and failure to complete a PIP) led to administrative leave and termination for insubordination and failure to communicate.
- Vannoy sued asserting: (1) FMLA interference (insufficient notice), (2) FMLA retaliation, and (3) ADA failure-to-accommodate and discriminatory discharge. The district court granted summary judgment to FRBR on all claims.
- The Fourth Circuit affirmed dismissal of the FMLA retaliation and ADA claims but vacated and remanded the FMLA interference claim because a factual dispute exists whether FRBR’s defective notice prejudiced Vannoy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference — sufficiency of individualized notice | FRBR failed to provide a rights-and-responsibilities notice that included job-restoration; omission prevented him from taking full leave (prejudiced him). | FRBR says it sent individualized notice and approved his FMLA leave; no prejudice because leave was granted. | Vacated summary judgment on this claim: genuine issue whether the notice omitted job-restoration and whether that omission prejudiced Vannoy (remand). |
| Receipt of notice | Vannoy asserts he never received the notice FRBR claims to have sent. | FRBR contends it emailed the notice to Vannoy. | Fourth Circuit did not resolve mailbox/receipt dispute but noted it could create a fact issue on remand. |
| FMLA retaliation — termination causally related to protected leave | Vannoy contends termination shortly after his leave request shows retaliation. | FRBR points to legitimate, nonretaliatory reasons: Baltimore misconduct, unauthorized absences, failure to complete PIP. | Affirmed district court: no pretext shown; legitimate reasons supported termination, so retaliation claim fails. |
| ADA — failure to accommodate / discriminatory discharge | Vannoy argues his disability-related needs were not accommodated and termination was discriminatory. | FRBR points to repeated misconduct and documented performance issues; ADA does not require retention despite misconduct even if related to disability. | Affirmed district court: ADA claims fail because FRBR legitimately disciplined/terminated for misconduct; employer had provided accommodations and efforts. |
Key Cases Cited
- Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (2002) (employee must show prejudice from FMLA notice violation to obtain relief)
- Lupyan v. Corinthian Colleges, Inc., 761 F.3d 314 (3d Cir. 2014) (prejudice can be shown by evidence plaintiff would have structured leave differently)
- Adams v. Anne Arundel County Public Schools, 789 F.3d 422 (4th Cir. 2015) (interference inquiry may examine employer actions short of denying leave)
- Dotson v. Pfizer, Inc., 558 F.3d 284 (4th Cir. 2009) (FMLA retaliation analyzed under McDonnell Douglas framework)
- Calhoun v. Dep’t of Labor, 576 F.3d 201 (4th Cir. 2009) (employer may discipline for misconduct even if employee engaged in protected leave)