Understanding Juday v. FCA US LLC (2023): Employer Lessons on FMLA Abuse Investigations

Introduction The Family and Medical Leave Act (FMLA) provides crucial protections for employees requiring medical leave. However, employers must balance these rights with ensuring that leave is used appropriately. The case of Juday v. FCA US LLC (2023) serves as a critical reminder that employers can challenge suspected FMLA abuse if done reasonably and in good faith.

In this case, FCA US LLC suspended an employee, Michael Juday, after an investigation revealed a suspicious pattern of concurrent FMLA leave with his spouse, also an FCA employee. Despite Juday’s claims of FMLA interference and retaliation, the court upheld the employer’s actions, emphasizing that a reasonable belief in misuse can justify disciplinary measures.

Key Takeaways from the Case

  1. Employers Have the Right to Investigate Suspicious FMLA Leave – The Seventh Circuit affirmed that an employer does not need definitive proof of fraud, only an honest and reasonable suspicion.

  2. Documentation and Due Diligence Matter – FCA reviewed leave records, conducted an internal investigation, and sought employee explanations before acting.

  3. FMLA Retaliation Claims Require Evidence of Bad Faith – The court found no proof that FCA acted dishonestly or retaliated against Juday for using FMLA leave.

  4. Consistency in Policy Enforcement Is Crucial – FCA demonstrated that its disciplinary actions followed established procedures, which strengthened its defense.

For employers, this case highlights the importance of having clear policies and a structured approach to handling FMLA leave concerns. Contact us at Lomond Legal to get your hands on a helpful checklist to ensure that investigations into suspected FMLA misuse are conducted fairly and legally.

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