Paula Crawford v. JPMorgan Chase & Co.
531 F. App'x 622
6th Cir.2013Background
- Paula Crawford worked for Chase (and predecessor Chemical Bank) as a Project Manager in Columbus; she also suffered PTSD/anxiety/depression after a 2005 workplace hostage event and took multiple periods of approved FMLA leave in 2007–2008.
- After returning from FMLA leave in February 2008, Crawford’s title was changed in March 2008 from Project Manager I to Quality Analyst II; Chase moved the Project Manager functions to Phoenix and reassigned Crawford to a Columbus-based role reporting to a former peer.
- Crawford alleges the new role had more clerical duties, required less legal expertise, and reduced advancement opportunities; Chase maintains salary, grade, hours, location, and bonus potential remained the same and asserts a business-driven elimination/transfer of the Project Manager position.
- Email communications among Chase managers show discussion of eliminating/moving the position to Phoenix without adding head count and consider reassignment options including making the role part-time or offering severance; some emails indicate hope Crawford would resign if offered the new role.
- Crawford sued asserting FMLA interference (failure to restore to equivalent position) and FMLA retaliation (adverse action for using FMLA). The district court granted summary judgment for Chase; the Sixth Circuit majority reverses and remands, dissent would have affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference: Was Crawford denied restoration to an equivalent position after FMLA leave? | Crawford says the Quality Analyst II role was not equivalent — more clerical, less legal expertise, diminished status and advancement. | Chase says pay, grade, hours, location, and benefits remained equivalent and it restored her to the same or equivalent position. | Reversed: fact issue exists whether positions were equivalent (duties/status differences may be material); summary judgment improper. |
| FMLA retaliation: Did Chase retaliate by transferring/eliminating her position shortly after leave? | Crawford cites temporal proximity, change to lesser role, and emails suggesting motive to push her out. | Chase offers legitimate business reason: eliminate/transfer position to Phoenix to avoid adding headcount. | Reversed: plaintiff made a prima facie showing; emails and timing create a fact issue as to pretext and causation. |
| Standard for "adverse action" in FMLA retaliation | Crawford urges adoption of Burlington standard (materially adverse to reasonable employee). | Chase disputes applicability or significance of job-change. | Adopted Burlington standard for FMLA retaliation; material adversity judged by whether action would dissuade reasonable worker. |
| Burden and summary judgment standard | Crawford: sufficient evidence to survive summary judgment on equivalency and retaliation pretext. | Chase: undisputed facts show equivalence and legitimate business reason, so judgment for employer. | Court finds genuine disputes of material fact (duties/status, emails, timing) — summary judgment improper. |
Key Cases Cited
- Cavin v. Honda of Am. Mfg., 346 F.3d 713 (6th Cir. 2003) (elements for FMLA interference claim)
- Arban v. West Publishing Corp., 345 F.3d 390 (6th Cir. 2003) (intent not required for FMLA interference)
- Wysong v. Dow Chemical Co., 503 F.3d 441 (6th Cir. 2007) (denial of FMLA benefits equates to adverse action)
- Burlington Northern & Santa Fe Ry. Co. v. White, 548 U.S. 53 (U.S. 2006) (materially adverse standard for retaliation adopted for FMLA claims)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for discrimination/retaliation claims)