Henne v. Great River Regional Library

Background

Great River Regional Library employed Julie Henne from August 2007 through September 2017. During the relevant period, Henne was the associate director of public relations and reported to the Library’s executive director, Karen Pundsack. Henne told Pundsack that she would take her spouse, who had terminal cancer, to chemotherapy appointments. Henne also told Pundsack that she was experiencing mental health challenges later diagnosed as anxiety and depression. After the Library placed Henne on a 30-day corrective-action plan, it terminated her employment on September 29, 2017.

Henne asserted claims under the Minnesota Human Rights Act, the Americans with Disabilities Act, and the Family and Medical Leave Act (FMLA). The Library sought partial judgment on the pleadings under Federal Rule of Civil Procedure 12(c), asking the court to dismiss Count VI, Henne’s FMLA claim.

Legal standard

A motion for judgment on the pleadings uses the same standard as a motion to dismiss for failure to state a claim. The court accepts the complaint’s factual allegations as true and draws reasonable inferences in the plaintiff’s favor, but it does not accept legal conclusions presented as facts. The complaint must allege enough facts to make the claim plausible.

FMLA notice and the spouse’s cancer

The FMLA provides eligible employees up to 12 workweeks of leave for certain reasons, including caring for a spouse with a serious health condition or dealing with the employee’s own serious health condition. Employers generally must notify an employee about eligibility for FMLA leave when the employee requests leave or when the employer learns that the employee’s leave may qualify under the FMLA.

Henne argued that the Library had to provide notice after learning that her spouse had cancer and that she would take him to chemotherapy appointments. The court noted that the complaint was unclear about whether Henne actually took leave while caring for her spouse. Henne had declined a suggested “leave of absence” because she could not afford unpaid leave and said she would use paid time off instead.

The court held that Henne’s claim failed because the complaint did not allege that she was prejudiced by the lack of FMLA notice. In particular, the complaint did not clearly allege that Henne took leave, that she would have taken FMLA leave if given the option, or how the alleged notice failure caused the damages she claimed. The court therefore concluded that Henne failed to state an FMLA-notice claim based on her spouse’s cancer treatments.

FMLA notice and Henne’s anxiety and depression

The court assumed, without deciding, that Henne’s anxiety and depression could qualify as serious health conditions under the FMLA. But the court found that Henne did not allege that those conditions prevented her from performing her job’s functions. Because the complaint did not allege that necessary circumstance, Henne did not state an FMLA-notice claim based on her own anxiety and depression.

Disposition

The court granted Great River Regional Library’s motion for partial judgment on the pleadings. It dismissed Count VI of the complaint without prejudice. The order’s stated disposition concerned the FMLA count.