Diaz v. Fort Wayne Foundry Corp.

In April 1995, Alfredo Diaz (plaintiff) took a month of Family and Medical Act (FMLA) leave from his job at Fort Wayne Foundry (the foundry) (defendant). Diaz’s first doctor certified that Diaz had bronchitis. Diaz later notified the foundry that he was recovering in Mexico. A second doctor in Mexico then certified that, due to several stomach and intestinal conditions, Diaz needed another month to recover. Because the conditions cited by each doctor appeared to be unrelated, the foundry grew suspicious and initiated a second-opinion process. The foundry sent a letter to Diaz’s home address in Indiana that instructed Diaz to report for a physical examination on June 8. Diaz did not appear for the appointment. The foundry fired Diaz on June 15 for failing to report to work. Diaz sued the foundry in federal district court, alleging that the foundry had violated Diaz’s FMLA rights. Diaz argued that the notice of the second-opinion examination was faulty because the foundry knew that Diaz was in Mexico. The foundry moved for summary judgment, arguing that a collective-bargaining agreement that bound both the foundry and Diaz had required the foundry to send the letter to Diaz’s last address of record—the Indiana address. The district court granted the foundry’s summary-judgment motion. Notably, the district court applied a McDonnell Douglas framework to evaluate Diaz’s FMLA claim. Diaz appealed.