McArdle v. Town of Dracut, Mass., No. 13-1044 (1st Cir. 2013)
Annotate this CaseAppellant was a former teacher in the town of Dracut, Massachusetts public schools. During the beginning of the 2009-2010 school year, Appellant failed to appear at school. Appellant subsequently applied for Family Medical Leave Act (FMLA) leave but did not notify the Dracut superintendent in writing of his request for FMLA leave, nor did he return a completed medical certification in accordance with Dracut's FMLA leave policy. On September 28, 2009, Appellant was terminated for abandoning his position. Appellant filed this suit in 2011 against individual decision-makers in the Dracut schools, alleging (1) violations of his rights under the FMLA; and (2) intentional infliction of emotional distress and intentional interference with advantageous business relations in violation of Massachusetts state law. The district court granted summary judgment for Defendants, concluding that Appellant had not worked enough to be eligible for FMLA leave and otherwise finding Appellant's claims meritless. The First Circuit Court of Appeal affirmed, holding (1) Appellant was not eligible for FMLA leave; (2) Appellant did not establish that Dracut's handling of his FMLA leave application caused him any harm; (3) Dracut did not unlawfully retaliate against Appellant; and (4) Appellant's state law claims against Defendants were without merit.
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