Tracy Walker v. Trinity Marine Products, 721 F.3d 542

Walker, a welder for Trinity Marine, was placed on FMLA leave by Trinity in May 2009 on an asserted serious health condition.
Trinity required medical certifications of fitness to return, and rejected initial certifications as inadequate.
A Vanderbilt physician later certified Walker as fit to work without restrictions.
Walker's third certification arrived after Labor Day 2009, but Trinity claimed she had exhausted FMLA leave and terminated her on September 8–9, 2009.
Walker filed suit on May 27, 2011, alleging FMLA interference and wrongful termination; the district court dismissed, and the Eighth Circuit affirmed de novo.
This appeal centers on whether Trinity interfered with FMLA rights and whether Walker’s termination was protected under the FMLA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Interference via involuntary leave	Walker alleges forced leave impermissibly interfered with FMLA rights.	Trinity did not interfere with Walker’s FMLA entitlement because it did not deny any FMLA leave she was entitled to.	Claim rejected; no interference with FMLA entitlement established.
Interference by refusing return after certifications	Walker argues continued denial to return after fitness certifications violated FMLA.	Walker had no FMLA right to restoration since she admitted no serious health condition.	No eligible FMLA right existed; claim fails.
Equitable estoppel to grant FMLA benefits	Walker seeks estoppel based on Trinity’s designation of her as seriously ill.	Estoppel requires detrimental reliance; Walker cannot show concrete detriment.	Equitable estoppel claim failings; no actionable detriment established.
Discrimination under FMLA for seeking restoration	Walker claims protected activity by attempting to restore her position.	No protected activity since she lacked a serious health condition defining FMLA eligibility.	No statutory protection; discrimination claim dismissed.

Wysong v. Dow Chemical Co., 503 F.3d 441 (6th Cir. 2007) (addressed forced leave doctrine as ripening upon later claim)
Sista v. CDC Ixis N. Am., Inc., 445 F.3d 161 (2d Cir. 2006) (forced leave alone does not by itself violate FMLA)
Pulczinski v. Trinity Structural Towers, Inc., 691 F.3d 996 (8th Cir. 2012) (FMLA enforcement provisions limit damages to actual monetary losses)
Blakley v. Schlumberger Tech. Corp., 648 F.3d 921 (8th Cir. 2011) (discrimination claim requires protected activity and adverse action)
Dormeyer v. Comerica Bank-Illinois, 223 F.3d 579 (7th Cir. 2000) (equitable estoppel in FMLA context; detrimental reliance required)
Reed v. Lear Corp., 556 F.3d 674 (8th Cir. 2009) (equitable estoppel considerations in FMLA)
Heckler v. Cmty. Health Servs. of Crawford Cnty., Inc., 467 U.S. 51 (Supreme Court 1984) (basic estoppel/detrimental reliance principles in statutory claims)
Duty v. Norton-Alcoa Proppants, 293 F.3d 481 (8th Cir. 2002) (restatement of FMLA damages and reliance concepts)
Quinn v. St. Louis Cnty., 653 F.3d 745 (8th Cir. 2011) (requires protected conduct and adverse action for discrimination claim)