Rebecca Sterling v. Board of Trustees, No. 20-3370 (8th Cir. 2022)
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Plaintiff worked at the University of Arkansas-Pulaski Technical College (“UAPTC”). In April 2018, Plaintiff requested and received leave under the Family and Medical Leave Act (“FMLA”) to care for her mother who had cancer. After being notified that her position would be eliminated in an upcoming reorganization she applied for a different position. The hiring committee led by Defendant interviewed Plaintiff and five other candidates. After the interview, the committee hired another applicant to whom Defendant had given a more favorable interview score.
Plaintiff sued the Board of Trustees of the University of Arkansas, members of the Board of the Trustees in their official capacities, the hiring committee director in his official and individual capacities, and UAPTC. Among other claims, she alleged that the hiring committee director violated the FMLA by discriminating and retaliating against her.
The district court denied the summary-judgment motion in relevant part, rejecting the hiring director’s qualified immunity defense on the ground that “qualified immunity is not available to defendants on an FMLA claim.” The Eighth Circuit remanded the case to the district court for consideration of the motion for summary judgment on the basis of qualified immunity. The court explained that the district court’s rejection of the hiring director’s qualified-immunity defense was based on a misreading of our statement in Darby v. Bratch. The court construed the statement in Darby about qualified immunity to mean that the FMLA clearly established the violative nature of the particular conduct in that case, not that qualified immunity can never be available on an FMLA claim.
Court Description: [Gruender, Author, with Colloton and Melloy, Circuit Judges] Civil case - Family and Medical Leave Act. Defendants appeal the district court's denial of their motion for summary judgment based on qualified immunity; the district court erred in holding that qualified immunity is not available to defendants on an FMLA claim - See Hager v. Arkansas Department of Health, 735 F.3d 1009 (8th Cir. 2013); because of this error, the district court did not apply the principles of qualified immunity to the facts presented, and the matter must be remanded for further consideration.
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