By Michelle High
On March 20, 2012 the U.S. Supreme Court issued a ruling in Coleman v. Court of Appeals of Maryland, that narrows state and municipal employees’ ability to collect damages for certain violations of the Family and Medical Leave Act. In its ruling, the U.S. Supreme Court held that states cannot be sued under the FMLA for failing to provide leave to an employee for his or her personal illness.
The Coleman case arises out of a situation wherein Daniel Coleman had sued his employer, the Maryland State Court of Appeals, for damages after he was fired in lieu of being provided ten days medical leave to address complications arising from hypertension and diabetes. The State of Maryland recognized it was bound by the FMLA, but claimed that its entitlement to sovereign immunity constitutionally barred any award of monetary damages from the state.
In its assessment of the case, the U.S. Supreme Court explained that a state may not be subject to suits for damages based upon violations of comprehensive statutes unless Congress has identified a specific pattern of Constitutional violations by a state employer. The Court explained that the “self-care” provision of the Family and Medical Leave Act was not intended to remedy a past pattern of discrimination by the states. Rather, the provision was enacted pursuant to the Commerce Clause. As such, the FMLA’s self-care provision is subject to states’ sovereign immunity.