United States Court of Appeals for the Fourth Circuit
272 F.3d 625 (4th Cir. 2001)
Howard Knussman (plaintiff) was a Maryland state trooper. Knussman’s wife was going through a complicated pregnancy and continued to have health-related problems after their child was born. A Maryland statute allowed state employees who were primary caregivers to use up to 30 days of sick leave to care for a newborn. The statute defined a primary caregiver as an employee who was primarily responsible for the care and nurturing of a child. The statute also allowed state employees who were secondary caregivers to use up to 10 days of sick leave to care for a newborn. Due to his wife’s health-related problems, Knussman requested 30 days of sick leave to care for his wife and newborn child. Knussman stated that he was performing the majority of the essential caregiving functions, such as diaper changing, feeding, bathing, and taking the child to the doctor. Jill Mullineaux (defendant), a member of the state police’s personnel division, denied Knussman’s request. In speaking to Knussman on the issue, Mullineaux stated that only women could be primary caregivers under the statute. Knussman brought suit against the State of Maryland, Mullineaux, and others (defendants), alleging a violation of the Equal Protection Clause of the Fourteenth Amendment. The trial court found that every state employee-defendant was entitled to qualified immunity, except Mullineaux, and ruled in favor of Knussman. Mullineaux appealed.
Rule of Law
Holding and Reasoning (Traxler, J.)
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