Legal Memorandum: Employment Discrimination Claim Review

Issue: Under federal law, what is the standard courts should apply in reviewing a claim for employment discrimination involving the Family and Medical Leave Act?

Area of Law: Employee Law, Litigation & Procedure
Keywords: Employment discrimination case; Family and Medical Leave Act
Jurisdiction: Federal
Cited Cases: 145 F.3d 986; 282 F. Supp. 2d 954
Cited Statutes: 29 U.S.C. § 2601
Date: 03/01/2004

One federal district court, analyzing an employer’s summary judgment motion in a case construing the Family and Medical Leave Act (“FMLA”), 29 U.S.C. § 2601, et seq., reiterated the standard of review in such cases:

Summary judgment is properly granted when the record, viewed in the light most favorable to the nonmoving party and giving that party the benefit of all reasonable inferences, shows that there is no genuine issue of material fact, and the moving party is entitled to judgment as a matter of law . . . The moving party must establish its right to judgment with such clarity that there is no room for controversy.

Jennings v. Mid-Am. Energy Co., 282 F. Supp. 2d 954, 959 (S.D. Iowa 2003).  Before the burden may shift to the nonmovant, the moving party bears the burden of demonstrating, based on pleadings, depositions, answers to interrogatories, admissions and affidavits, that there is an absence of a genuine issue of material fact.  Id. at 959.

In summary judgment proceedings in an employment case, “this Court has but one task, to decide, based on the evidence of record as identified in the parties’ moving and resistance papers, whether there is any material dispute of fact that requires a trial.”  Id. at 958.  The parties share the burden of identifying which evidence will facilitate this assessment.  Id.

The Jennings Court repeated the Eighth Circuit Court of Appeals’ “repeated[] caution[]”  that in employment actions, which are inherently fact-based, “summary judgment should ‘seldom […]

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