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Ballard v. Chicago Park District
United States Court of Appeals for the Seventh Circuit
741 F.3d 838 (7th Cir. 2014)
Beverly Ballard (plaintiff) was an employee for Chicago Park District (CPD) (defendant). Beverly’s mother, Sarah Ballard, was terminally ill with congestive heart failure. Beverly lived with Sarah as her primary caregiver, which involved cooking for Sarah, administering Sarah’s medication, and bathing and dressing Sarah. In 2007, Sarah received funding for a family trip to Las Vegas to fulfill one of Sarah’s end-of-life goals. Beverly requested unpaid leave to accompany Sarah, but CPD denied the request. Beverly accompanied Sarah on a six-day trip to Las Vegas in 2008. During the trip, Beverly continued to perform her usual caregiving responsibilities. Several months later, CPD terminated Beverly’s employment for her unauthorized absences during the trip. Beverly sued under the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. § 2601 et seq., arguing that Beverly was entitled to unpaid leave to care for her terminally ill mother during the trip. CPD moved for summary judgment, arguing that Beverly was not entitled to FMLA leave, because the trip was not related to continuing medical treatment. The district court denied the motion, finding that the location of care did not affect FMLA coverage. CPD filed an interlocutory appeal.
Rule of Law
Holding and Reasoning (Flaum, J.)
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