| A federal appeals court ruling in favor of the employer | | | | tired in the afternoon. She made no formal |
| is based on an employee's obligations under the FMLA. | | | | arrangements with Riverside to leave early nor did she |
| The Decision | | | | request intermittent leave. She continued to work less |
| In Ridings v. Riverside Medical Center, the Seventh | | | | than full days the remainder of 2003. |
| Circuit Court of Appeals (which has jurisdiction over | | | | In January 2004, Riverside told Ridings several times |
| Illinois, Indiana and Wisconsin) ruled that: | | | | that she needed to work full days on the premises or |
| - for intermittent or reduced schedule leave under the | | | | submit medical documentation to request FMLA leave. |
| FMLA, the employee must present 1) the dates that | | | | Ridings ignored these requests and maintained that |
| planned medical treatment is expected, 2) the duration | | | | since she brought work home with her, she was |
| of treatment, and 3) the doctor's statement of the | | | | working full-time. |
| medical necessity for the type of leave requested and | | | | In March 2004, Ridings finally provided a doctor's note |
| the expected duration of the leave. | | | | which stated that she "could not work an eight-hour |
| - an employer is entitled to ask a full-time employee to | | | | day because of a medical condition until further notice." |
| work a full-time schedule on the premises. The | | | | Riverside provided her with a Certificate of Health |
| employer (Riverside) gave the employee (Ridings) the | | | | Care Provider form (CHCP) and advised that she |
| choice of working a full schedule on the premises or | | | | needed to return it within 15 days. |
| completing her FMLA paperwork. She did neither. | | | | After Ridings failed to provide the completed CHCP, |
| The court found that Ridings' termination was justified | | | | despite several requests and written warnings, Ridings |
| for absenteeism or insubordination under Riverside's | | | | was suspended for three days without pay. She was |
| policies. | | | | advised that if she did not return the CHCP upon |
| Case Facts | | | | returning to work after the suspension, further action, |
| Ridings was an employee of Riverside Medical Center | | | | up to and including termination, may be taken. Ridings |
| from October 1998 until May 13, 2004 as a database | | | | returned to work without the completed CHCP and |
| operator. In December 2002, Ridings was diagnosed | | | | Riverside terminated her employment. |
| with Graves' disease, and in January 2003, she was | | | | Ridings sued Riverside for interference with her rights |
| granted two weeks of FMLA leave following surgery | | | | and retaliation in violation in the FMLA. The district court |
| to remove her thyroid. She was also granted an | | | | granted summary judgment for Riverside and Ridings |
| extension of an additional week of leave. | | | | appealed. The appellate court affirmed summary |
| She returned to work in February 2003, leaving early | | | | judgment for Riverside on both the interference and |
| because she alleged that her medications made her | | | | retaliation claims. |