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Volatile Work Relationship Undermines FMLA Claim

Heidi Germanowski and Patricia Harris had a particularly tense relationship. They worked together well for many years until Ms. Harris became the register of deeds and direct supervisor. At that point, their relationship began to come apart. The stress of this situation became a problem for Ms. Germanowski and she sought medical treatment.

At some point, the register purportedly pressured Ms. Germanowski to provide financial support for a particular official. At first she refused, but ultimately made a donation when Ms. Harris reassigned her job duties and left her out of meetings. Ms. Germanowski was then diagnosed with an anxiety disorder. This diagnosis was followed with a nervous breakdown at work. The register drove Ms. Germanowski home while the she blamed the register for her condition. Ms. Harris chastised Ms. Germanowski for her disloyalty and for inappropriately discussing her anxiety with co-workers. The register recommended that Ms. Germanowski take another week off. She did return to work and was able to work for a couple of weeks. When Ms. Germanowski mentioned that she had a sports pistol and she became upset when the register asked her if she was having an affair, the register told her not to return to work the next day. She was thereafter denied access to the building. Afraid for her job, Ms. Germanowski went to doctor who wrote a note on her behalf. She was fired before she was able to submit the note.

The First Circuit Court of Appeals heard an appeal of Ms. Germanowski’s Family and Medical Leave claim. The circuit court noted that the events could arguably have given notice to her employer that she might be asking for FMLA leave. However, it did not plausibly cause her termination. Ms. Germanowski’s own allegations reflected that her termination was likely already in the works. The register had accommodated her previously when she was unable to work. Her problematic employment history overcame the temporal relationship between her leave note and her firing.