Dalton v. Manor Care of West Des Moines, LLC, No. 13-3743 (8th Cir. 2015)
Annotate this CaseNurse Dalton was terminated from her supervisory position at the ManorCare skilled nursing facility. Dalton alleged interference with her statutory rights under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601, and discrimination based on her Chronic Kidney Disease disability in violation of the Iowa Civil Rights Act, Iowa Code Ch. 216, and the Americans with Disabilities Act, 42 U.S.C. 12101. ManorCare claimed that nurses that Dalton supervised had complained about her job performance and that Dalton had received a Third/Final Written Warning for violating Major/Type B Work Rules, citing inappropriate negative comments about her work at the nurses’ station, where patients could overhear; failure to notify staff members she had cancelled a meeting; and taking an extended lunch break and failing to attend patient care conferences. There were also problems with attendance and late reports. Dalton understood that any further performance-related issue could result in termination. The district court dismissed all claims. The Eighth Circuit affirmed. Dalton’s termination was the end of an on-going, unrelated disciplinary process.
Court Description: Civil case - Family Medical Leave Act. Plaintiff failed to establish that she suffered from a serious health condition resulting in an inability to work; her short-term conditions did not rise to the level of a serious health condition and the FMLA did not protect her from discipline based on her failure to complete work; even if plaintiff had a chronic serious health condition so that a hospital visit was FMLA-protected, the district court did not err in granting the defendant's motion for summary judgment because defendant terminated plaintiff for reasons other than her work absences.
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