Tricia Basch v. Knoll, Inc., 619 F. App'x 457

Basch, after long employment, was discharged by Knoll amidst an FMLA leave history.
On November 9, 2011 Basch, in the paint lines, refused to re-kit a basket after being told to by supervisor Walker.
Basch purportedly called other managers; she did not re-kit the basket.
Basch sought FMLA leave citing stress; HR advised leave could not be taken due to suspension, and Basch was discharged two days later.
Basch asserted multiple claims under the ADA, FMLA, Title VII, and Michigan law; the district court granted summary judgment on all claims.
The court reviews the FMLA retaliation claim de novo to determine if there is no genuine dispute of material fact.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie case of FMLA retaliation	Basch asserts protected activity and causation via timing.	Knoll contends no causal link; multiple-year leave history weakens proximity.	No prima facie retaliation established.
Pretext for discharge	Discharge was pretextual due to FMLA use and atmosphere.	Discipline based on insubordination with factual basis; not pretext.	Rationale for discharge not shown to be pretextual.

Edgar v. JAC Prods., Inc., 443 F.3d 501 (6th Cir. 2006) (establishes burden-shifting framework for FMLA retaliation)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Sup. Ct. 1973) (burden-shifting framework for discrimination cases)
Mickey v. Zeidler Tool & Die Co., 516 F.3d 516 (6th Cir. 2008) (temporal proximity must be near in time to establish causation)
Seeger v. Cincinnati Bell Tel. Co., 681 F.3d 274 (6th Cir. 2012) (test for pretext considers basis in fact, motivation, and sufficiency)
Donald v. Sybra, Inc., 667 F.3d 757 (6th Cir. 2012) (proximity alone cannot establish causation for pretext)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (Sup. Ct. 1986) (summary judgment standard requires genuine dispute to be triable)