Yasin Reeder v. County of Wayne, 694 F. App'x 1001

Reeder, a Wayne County jail officer for ~15 years, developed anxiety, chest pain, and related symptoms in 2013–2014 that his doctors said restricted him to eight-hour workdays.
He repeatedly refused mandatory overtime citing drowsiness/dizziness and his doctors’ notes; Personnel received three medical notes but did not notify him of FMLA rights or request medical certification.
Reeder was disciplined multiple times for refusing overtime, suspended, and ultimately terminated effective May 7, 2014.
Reeder sued alleging, among other claims, FMLA interference for the County’s failure to give required notice and to process his leave; the jury awarded $187,500 on the FMLA interference claim.
On appeal the County argued (1) the trial court gave an erroneous answer to a jury question about whether employer inaction can constitute interference, and (2) the court erred in denying judgment as a matter of law because Reeder allegedly failed to give adequate notice of intent to take FMLA leave.
The Sixth Circuit affirmed, holding the jury question answer was not an abuse of discretion and that sufficient evidence supported letting the interference claim go to the jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court’s answer to a jury note improperly allowed a finding that employer inaction alone is FMLA interference	Reeder: jury could decide whether County’s failure to advise about FMLA and paperwork was interference	County: inaction cannot as a matter of law constitute interference; court should have reiterated regulatory notice language	Affirmed — objection not preserved; court’s neutral answer effectively sent jury back to existing instructions and was not confusing or prejudicial
Whether Reeder gave sufficient notice to trigger County’s duty to advise/request certification under FMLA	Reeder: delivering three medical notes to Personnel amounted to sufficient notice that FMLA-qualifying leave was sought	County: Reeder never requested FMLA, did not follow County’s leave-procedure, and sometimes worked >8 hours so no entitlement	Affirmed — factual question for jury; evidence (three provider notes and communications to Personnel) could reasonably support notice and obligation to inquire

Ventas, Inc. v. HCP, Inc., 647 F.3d 291 (6th Cir. 2011) (standards for reviewing jury instructions)
Wallace v. FedEx Corp., 764 F.3d 571 (6th Cir. 2014) (employer inaction in failing to give FMLA notice may support interference if it causes harm; employee notice burden is low)
Donald v. Sybra, Inc., 667 F.3d 757 (6th Cir. 2012) (elements of an FMLA interference claim)
Smith v. Rock‑Tenn Servs., Inc., 813 F.3d 298 (6th Cir. 2016) (standard of review for judgment as a matter of law)
Kobus v. College of St. Scholastica, 608 F.3d 1034 (8th Cir. 2010) (distinguishable; plaintiff expressly disclaimed FMLA when given form)
Hayward v. Cleveland Clinic Found., 759 F.3d 601 (6th Cir. 2014) (preservation rule for jury instruction objections)
Balsley v. LFP, Inc., 691 F.3d 747 (6th Cir. 2012) (standard for Rule 50 review)
United States v. Harrod, 168 F.3d 887 (6th Cir. 1999) (reversal standard when instruction error alleged)