Marlene Dawkins v. Fulton County Government, 733 F.3d 1084

Dawkins was Fulton County's Building Maintenance Manager, temporarily reassigned to Building Mechanic Manager for 90 days starting Sept 26, 2007 with a 10% raise.
On Oct 18, 2007 Dawkins emailed manager Stokes requesting emergency leave and an FMLA packet for a terminally ill uncle; Yearby and Jones were copied.
Stokes responded two hours later with “Approved,” but it is disputed whether this approved leave was for FMLA eligibility or emergency leave.
Fulton County policy requires an FMLA packet and doctor certification before FMLA leave is approved; care for a terminally ill uncle is not FMLA-covered.
On Oct 22, 2007 Dawkins’s temporary reassignment was rescinded due to her absence; she returned to her original role on Nov 5, 2007; later compensation of $827.90 was paid during an EEOC investigation.
The district court granted summary judgment for the Defendants on all claims; Dawkins sought relief under a theory of federal common law equitable estoppel to extend FMLA coverage for an unqualified absence; the court assumed estoppel could apply but found no evidence of reasonable and detrimental reliance, so summary judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal common law equitable estoppel extends FMLA coverage.	Dawkins argues estoppel should apply to make her FMLA leave eligible.	Defendants contend Dawkins failed to prove the required estoppel elements, especially reliance.	No, the court upheld summary judgment for lack of reliance; applicability of estoppel to FMLA left undecided.

Busby v. JRHBW Realty, Inc., 513 F.3d 1314 (11th Cir. 2008) (five-element estoppel framework; awareness of true facts is an element)
Heckler v. Cmty. Health Servs. of Crawford Cnty., Inc., 467 U.S. 51 (U.S. 1984) (estoppel requires reasonable reliance; authority limits)
Martin v. Brevard County Public Schools, 543 F.3d 1261 (11th Cir. 2008) (assumes Busby elements; context for FMLA estoppel)
Dobrowski v. Jay Dee Contractors, Inc., 571 F.3d 551 (6th Cir. 2009) (recognizes equitable estoppel in FMLA cases in certain circuits)
Murphy v. FedEx Nat’l LTL, Inc., 618 F.3d 893 (8th Cir. 2010) (estoppel requires reasonable reliance in FMLA context)
Minard v. ITC Deltacom Commc’ns, Inc., 447 F.3d 352 (5th Cir. 2006) (employee reliance on employer's FMLA representation can estop)
Kosakow v. New Rochelle Radiology Assocs., P.C., 274 F.3d 706 (2d Cir. 2001) (silence can mislead about FMLA rights in estoppel)
Trane Co. v. Whitehurst-Lassen Constr. Co., 881 F.2d 996 (11th Cir. 1989) (constructive/knowledge standards in estoppel)