Federal Appeals Court Allows Georgia Schoolteacher to Pursue FMLA Claim Following Termination

The 11th Circuit Court of Appeals in Atlanta issued a ruling that will likely make it easier for Georgia public school employees to pursue lawsuits against their employers for violations of federal employment laws like the Family and Medical Leave Act. The ruling concluded that public school districts are not “arms of the state” government, which means that they are not immune from federal employment actions, such as the FMLA case launched by a Georgia high school teacher who was terminated for her use of FMLA leave to deal with the effects of her sickle cell anemia.

The case involved the termination of Zaneta Lightfoot from her job with the Henry County School District south of Atlanta. Lightfoot began as an English and drama teacher, and cheerleading coach, at Woodland High School in 2007. The teacher had sickle cell anemia, which caused her to experience bouts of extreme pain and weakness. Lightfoot asked for and received permission to take intermittent periods off from work under FMLA when her condition made working untenable during the 2010-11 school year.

In the spring semester of that year, however, the school issued Lightfoot a disciplinary letter and later handed her a negative performance evaluation, allegedly based upon her use of FMLA leave. The next year, the school district terminated Lightfoot. The teacher sued for employment discrimination, accusing the district of violating both the Americans with Disabilities Act and FMLA. The district attempted to defeat the lawsuit by arguing that as a public school system, it was a part of the government of the State of Georgia and immune to these types of lawsuits thanks to the 11th Amendment to the US Constitution.

The trial court agreed with the district’s argument, but the 11th Circuit reversed that decision. Although the teacher did not present a sufficient basis for an ADA claim, her FMLA action should have been allowed to proceed.

The court explained that several factors governed whether or not an entity was an “arm of the state” and, as a result, immune under the 11th Amendment. The school board maintained local control over decision-making within the district’s schools, and it also held considerable autonomy under state law with regard to the management of the district. Additionally, any legal judgments against the district were the district’s responsibility, not the state’s. All of these criteria weighed against the district’s argument. Even though public school districts like Lightfoot’s employer received substantial funding from the state, this alone was not enough to make a public school district an “arm of the state.”

The ruling in Lightfoot’s case strengthens the position of public school employees in Georgia who believes their employers have violated federal employment law. Whether you are an employee or an employer, when you need advice and representation regarding FMLA, discrimination, or other employment law issues, you should contact the skilled Georgia FMLA attorneys at Parks, Chesin & Walbert. Our experienced attorneys can help you understand your rights and obligations under the law.

To speak with one of our lawyers about your case, call 404-873-8048.

More blog posts:

Definition of “Spouse” Under FMLA Amended to Include Same-Sex Couples, Atlanta Employment Attorneys Blog, March 18, 2015

Eleventh Circuit Affirms Georgia Truck Driver’s Termination Did Not Violate ADA, FMLA, Atlanta Employment Attorneys Blog, Feb. 11, 2015

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