Employer prevailed on all claims. Trial court properly declined to instruct jury on FMLA interference claim due to lack of evidence of FMLA request, and jury returned verdict for defendant on remaining disability discrimination and retaliation claims under state and federal law.
The plaintiff sought to recover damages from the defendant for, inter alia, disability discrimination pursuant to the Connecticut Fair Employment Practices Act (§ 46a-51 et seq.) and for interference with the Family and Medical Leave Act of 1993 (29 U.S.C. § 2601 et seq.) following the termination of her employment. The plaintiff was first hired by the defendant in 1995 but her position was eliminated and she was termi- nated in June, 2015. The plaintiff was rehired for a new position in August, 2015, and was subject to a probationary period for her first 120 days at work. In September, 2015, the plaintiff injured her left knee and lower back while at work. The plaintiff was placed on modified work duty but was eventually placed on an indefinite leave of absence and remained on leave until October, 2015. She missed additional work in November, 2015, after she experienced a flare-up of her knee injury. All of the time that she missed from work was considered workers' compensation leave by the defendant. The plaintiff received two negative performance evaluations in January and February, 2016, based solely on her performance while she was at work. The plaintiff was terminated for her poor job performance in March, 2016. During the trial on the plaintiff's complaint, the trial court declined to instruct the jury on the plaintiff's FMLA interference claim, concluding that there was no evidence to support the claim that the plaintiff made an FMLA request to the defendant. On the plaintiff's remaining claims, the jury returned a verdict for the defendant and the court rendered judgment in accordance with the verdict, from which the plaintiff appealed to this court. Held: 1. The trial court properly declined to charge the jury with regard to the plaintiff's claim of interference with the Family and Medical Leave Act of 1993: the plaintiff failed to satisfy the preliminary requirement for the court to consider her interference claim, namely, that she made an initial showing
Monts v. Board of Education – Summary
What Happened
A former employee of Hartford's Board of Education was let go in 2015 after working there since 1995. She sued the school district, claiming she was fired because of a disability, treated unfairly in retaliation, and not given proper accommodations for her medical needs. She also argued the district violated federal law by interfering with her right to take medical leave.
What the Court Decided
The court sided completely with the school district. The judge found no evidence that the employee had formally requested medical leave, so that claim couldn't even go to a jury. A jury then reviewed the remaining claims about disability discrimination and retaliation and decided in favor of the employer. The employee received no money damages.
Why This Matters for Workers
This case shows that workers must take specific steps to protect themselves. Simply having a disability or medical condition isn't enough—employees need to formally request accommodations and medical leave in writing. Workers should document their requests and keep records showing they've properly notified their employer of their needs.
This summary was generated to explain the ruling in plain English and is not legal advice.
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