Michniewicz v. METASOURCE, LLC, 756 F. Supp. 2d 657

Michniewicz and Keough, former Metasource employees, alleged FMLA interference and retaliation claims arising from terminations while on FMLA leave.
Both women were on medical leave in 2009 (Michniewicz neck surgery; Keough cyst removal) and were terminated June 15, 2009.
Metasource reduced its workforce due to decreased client demand and later acquired Capture Resources; Doyle supervised preppers and led reductions.
After the May 2009 merger, Metasource reportedly added Capture Resources preppers, while Doyle had been evaluating performance, attendance, and efficiency to select layoffs.
Plaintiffs claimed there were available positions post-RIF and that the reductions were pretextual; Metasource argued the terminations were a bona fide RIF based on performance and workload.
The court denied summary judgment on both interference and retaliation claims, finding genuine disputes of material fact regarding the legitimacy of the RIF and potential pretext.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was a genuine reduction in force justifying termination	Michniewicz argued RIF was not genuine and that positions remained or expanded post-acquisition.	Metasource contended terminations were due to a legitimate RIF caused by reduced workload.	Disputes of material fact exist; summary judgment denied.
Whether the terminations violated the FMLA interference provisions	Plaintiffs claim they were denied FMLA benefits and reinstatement due to being on leave.	Terminations were based on RIF and not on FMLA status; no denial of FMLA rights occurred.	Questions of fact remain about entitlement and reinstatement; interference claims survive.
Whether there is a causal link showing retaliation under the FMLA	Terminations shortly after FMLA leave and Doyle's discriminatory remarks indicate retaliation.	Proffered non-discriminatory RIF reason undermines retaliation claim; timing alone is insufficient.	Pretext and causation issues remain; retaliation claims survive summary judgment.

Conoshenti v. Pub. Serv. Elec. & Gas Co., 364 F.3d 135 (3d Cir. 2004) (defines FMLA rights and reinstatement requirements)
Sarnowski v. Air Brooke Limousine, Inc., 510 F.3d 398 (3d Cir. 2007) (interference standard—need only show denied benefits)
Callison v. City of Philadelphia, 430 F.3d 117 (3d Cir. 2005) (interference claim framework and non-discrimination focus)
Kautz v. Met-Pro Corp., 412 F.3d 463 (3d Cir. 2005) (pretext framework in FMLA retaliation context)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext framework for proving discrimination)
Weston v. Pennsylvania, 251 F.3d 420 (3d Cir. 2001) (pretext evidence relevance to causation in retaliation)