Where a plaintiff has alleged retaliation in violation of the Family and Medical Leave Act, the defendant employer should be awarded summary judgment, as no reasonable jury could find that the defendant terminated the plaintiff because he took FMLA leave.
“Plaintiff, Randy Fowler (‘Plaintiff’ or ‘Fowler’), originally brought a claim in the Wayne County Circuit Court against Defendant, Metz Culinary Management (‘Defendant,’ ‘Metz,’ or ‘the Company’), for retaliation in violation of the Family and Medical Leave Act, 29 U.S.C. §2601 et seq. (‘FMLA’). … After which, Defendant removed the case to federal court. …
“Starting in October 2023, Plaintiff began reporting to William Harvey (‘Harvey’) ‘who was hired to be the District Manager over Plaintiff’s region.’ …
“Plaintiff’s employment with Metz ended on January 29, 2024, pursuant to a Separation Notice (‘the Notice’). …
“… Defendant takes the position that there is no direct evidence in this case because ‘Plaintiff can point to no credible direct evidence that Plaintiff’s FMLA leave was a motivating factor in Plaintiff’s termination.’ … Defendant is correct. …
“… Without drawing at least some inferences, a factfinder could not reasonably find that the Notice evidences discriminatory motive. Nor has Plaintiff identified any specific comments by Defendant or Harvey which may constitute direct evidence of FMLA retaliation. Given the lack thereof, Plaintiff’s claims cannot proceed on a direct evidence theory. …
“… Defendant contends that Plaintiff cannot establish a prima facie case because there is no causal connection between exercising his FMLA rights and Metz’s termination of Plaintiff’s employment. …
“Here, the undisputed factual record does not support a causal connection finding; and on the record currently before this Court, no reasonable jury could find that Metz terminated Fowler because he took FMLA leave. Consequently, Fowler cannot establish a prima facie case, and his sole claim in this action fails as a matter of law. …
“… According to Metz, its legitimate, non-discriminatory reason for terminating Fowler was because he informed the Company that he was seeking other employment. …
“… While Plaintiff may consider Defendant’s decision to ‘sell its soul’ problematic, such allegation does not give rise to an actionable cause of action. So, even if Plaintiff could satisfy the causal connection element of his prima facie case—which he cannot—the Court finds that he still cannot show that Defendant’s legitimate, nondiscriminatory reason for his termination is mere pretext. Fowler’s FMLA claim is therefore dismissed. …
“IT IS HEREBY ORDERED that Plaintiff’s Partial Motion for Summary Judgment (ECF No. 13) is DENIED and Defendant’s Cross-Motion for Summary Judgment (ECF No. 14) is GRANTED.”