NJ District Court upholds employee termination after FMLA leave

On March 31, 2023, the U.S. District Court for the District of New Jersey granted an employer’s request for dismissal, rejecting a former employee’s allegations of discrimination and retaliation under the Family and Medical Leave Act (FMLA), the Americans with Disabilities Act (ADA), and the New Jersey Law Against Discrimination (NJLAD).

Facts

Carmelita LeBlanc began her career with Jefferson Health New Jersey (Jefferson Health) in May 2015 as a nurse manager in the hospital’s intensive care and intermediate care units. During her employment, she had a well-documented history of hostile and unprofessional work performance. Coworkers reported she was reactive, often yelling at other nurses and team members. She also had an unusually high rate of employee turnover, and survey data revealed a lack of employee engagement and dissatisfaction, reflecting her management skills.

In February 2020, LeBlanc was advised of a human resources (HR) investigation. Soon after, she met with HR to discuss a corrective action plan (CAP) that included training and resources to improve her communication and management skills.

She was scheduled to take leave under the Family and Medical Leave Act (FMLA) later in the month to undergo knee replacement surgery, so she and HR agreed that CAP training would start after she returned from leave. When she returned in May 2020 without restrictions, she met with HR weekly to discuss the CAP. She completed the required training and successfully met the CAP’s goals, agreeing with HR that the training was a positive experience.