Wayland v. OSF Healthcare System, No. 23-1541 (7th Cir. 2024)
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The case involves an appeal by Marianne Wayland against her former employer, OSF Healthcare System. Wayland alleged that OSF violated her rights under the Family and Medical Leave Act (FMLA) by failing to adjust performance expectations to reflect her reduced hours while she was on approved medical leave, and subsequently firing her. The U.S. District Court for the Central District of Illinois granted summary judgment in favor of OSF, concluding that it fired Wayland for justifiable reasons based on her performance.
Wayland appealed this decision arguing that there was a genuine dispute of material fact over the amount of approved leave she took. The Circuit Court agreed, finding that if Wayland's testimony about the amount of leave she took is believed, a jury could find that OSF unlawfully failed to adjust its performance expectations by properly accounting for her leave when evaluating her.
The Circuit Court also noted that a jury could potentially find that OSF interfered with or retaliated against Wayland's use of leave by holding her to the same standards as when she worked full time, and then firing her for falling short. It found that there was sufficient evidence to raise a genuine question about whether OSF's reasons for firing Wayland were pretextual, highlighting that OSF did not tell Wayland that poor performance would lead to discharge and set goals that were potentially impossible to meet.
The Circuit Court vacated the district court's judgment and remanded the case for further proceedings.
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