Paylor v. Hartford Fire Ins. Co., No. 13-12696 (11th Cir. 2014)
Annotate this CasePlaintiff filed suit against her former employer, Hartford, alleging claims of interference and retaliation under the Family Medical Leave Act of 1993 (FMLA), 29 U.S.C. 2601, et seq. The court rejected plaintiff's interpretation of "prospective" FMLA rights and concluded that section 825.220(d)'s prohibition of "prospective" waiver means only that an employee may not waive FMLA rights, in advance, for violations of the statute that have yet to occur. Here, the conduct plaintiff complained about all happened before she signed the Severance Agreement. In signing the agreement and accepting her severance benefits, plaintiff settled claims based on past employer conduct, and so the district court did not err in concluding that the agreement was valid and that it entitled Hartford to judgment as a matter of law. The court also concluded that the district court did not err in concluding that plaintiff executed the Severance Agreement knowingly and voluntarily. Accordingly, the court affirmed the judgment of the district court.
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