Reyer v. Saint Francis Country House, 243 F. Supp. 3d 573

Background

Reyer, a long‑time Maintenance Worker at Saint Francis, suffered from COPD/emphysema and took intermittent and extended FMLA leave in 2011–2013; he had a PICC line and a temporary 5‑pound lifting restriction in late 2013.
Employer handbook provided 12 weeks of FMLA and a separate up to six‑month medical leave; Reyer repeatedly sought FMLA balance information from HR but claims he was not given adequate notice of FMLA designation or remaining balance.
Reyer submitted doctor notes indicating return‑to‑work with a 5‑pound lifting limit and emailed HR that he could return December 9, 2013; HR managers disputed whether they received clear or consistent return‑date information.
On December 23, 2013 (treated as the date his FMLA expired), Saint Francis terminated Reyer, citing exhausted FMLA, inability to perform essential functions (lifting), and overtime/understaffing; Reyer disputes these reasons and contends failure to accommodate and retaliation.
The court found genuine disputes of material fact on whether employer provided required FMLA notices, whether lifting >50 lbs. was an essential function, whether defendant engaged in the interactive process or considered the six‑month medical leave policy, and whether proffered reasons were pretext.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
FMLA interference — failure to give required FMLA notices / information	Reyer says employer never gave designation notice, didn’t inform him of FMLA balance, preventing informed choices	Employer contends Reyer received/used FMLA each year and was not denied benefits; he failed to provide return‑to‑work certification	Denied summary judgment: factual disputes about whether employer provided required individual FMLA notices survive trial
FMLA retaliation — causal link between leave and termination	Reyer argues termination coincided with exhaustion of FMLA and employer failed to consider additional 6‑month leave, supporting causation and retaliation	Employer points to long history of leave (since 2011), argues timing isn’t unusually suggestive and termination was for exhausted leave/ inability to return	Denied summary judgment: timing (termination when leave ended) and other facts permit jury inference of causation; employer’s nondiscriminatory reasons can be viewed as pretext
ADA disparate treatment — whether Reyer was a "qualified individual" (essential functions)	Reyer contends he could perform essential functions with accommodations and lifting >50 lbs. may be a means, not the essential function	Employer relies on written job description and testimony that lifting >50 lbs. is required/essential for maintenance work	Denied summary judgment: genuine disputes whether lifting >50 lbs. was an essential function and whether Reyer could perform job with reasonable accommodation
ADA failure to accommodate / interactive process & ADA retaliation	Reyer says he requested accommodation (temporary 5‑lb restriction or short additional leave), employer failed to meaningfully engage or consider finite accommodation; termination was retaliatory	Employer says it evaluated restriction, found no reasonable accommodation given job demands and believed restriction was indefinite	Denied summary judgment: factual disputes about duration of restriction, adequacy of employer’s interactive process, and pretext preclude judgment as a matter of law

Key Cases Cited

Lupyan v. Corinthian Colleges Inc., 761 F.3d 314 (3d Cir. 2014) (FMLA entitlement and restoration principles; employer notice obligations)
Conoshenti v. Pub. Serv. Elec. & Gas Co., 364 F.3d 135 (3d Cir. 2004) (failure to provide required FMLA notice can constitute interference if it prevents meaningful exercise of rights)
Callison v. City of Philadelphia, 430 F.3d 117 (3d Cir. 2005) (distinguishing FMLA interference and retaliation claims)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden‑shifting framework for discrimination/retaliation cases)
Skerski v. Time Warner Cable Co., 257 F.3d 273 (3d Cir. 2001) (factors for identifying essential job functions)
Turner v. Hershey Chocolate U.S., 440 F.3d 604 (3d Cir. 2006) (fact questions on essential functions and reasonable accommodation)
Budhun v. Reading Hosp. & Med. Ctr., 765 F.3d 245 (3d Cir. 2014) (FMLA retaliation rooted in regulation; protection for exercising FMLA rights)
Sheridan v. E.I. DuPont de Nemours & Co., 100 F.3d 1061 (3d Cir. 1996) (pretext determinations generally for the jury)