Rynders v. Williams, No. 10-3466 (8th Cir. 2011)
Annotate this CasePlaintiff sued Judge Larry Williams for wrongful termination, in violation of plaintiff's rights under the First Amendment and the Family Medical leave Act (FMLA), 29 U.S.C. 2601, et seq. Plaintiff appealed the district court's grant of summary judgment in favor of Williams. The court held that a genuine issue of material fact existed as to whether Williams terminated plaintiff's employment because of the letter plaintiff wrote to the editor of a local paper in 2007 regarding the judge's financial committee. The court also held that the district court properly granted summary judgment in favor of Williams in his individual capacity on plaintiff's FMLA claims where plaintiff failed to argue how Williams personally received adequate notice and, given the undisputed record that Williams generally delegated the operation of the Road Department to others. Therefore, the court held that the district court erred in granting summary judgment against plaintiff on his First Amendment claims; erred in granting summary judgment against plaintiff on his official-capacity claims under the FMLA; but properly granted summary judgment against plaintiff on his individual-capacity FMLA claims against Williams.
Court Description: Civil Case - Family Medical Leave Act. Because a genuine issue of material fact exists whether Rynders was terminated because a letter he wrote to the editor, grant of summary judgment in favor of County Judge Williams is reversed. District court should have considered the extent to which Williams set Road Department policy before granting summary judgment and should do so on remand. Grant of summary judgment on claim of interference and retaliation under FMLA is also reversed, as factual dispute exists whether Williams in his official capacity received notice of Rynders's need for FMLA leave. Summary judgment was properly granted to Williams in his individual capacity on the FMLA claims. Judge Ericksen dissents in part.
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