Woods v. START Treatment & Recovery Centers, Inc.

Cassandra Woods (plaintiff) was a substance-abuse counselor at START Treatment & Recovery Centers, Inc. (START) (defendant). A critical part of Woods’s job was to promptly draft and file notes for each counseling session; however, Woods failed to meet note-keeping requirements. Woods was issued several performance-based warnings and was ultimately placed on probation, but her performance failed to substantially improve. At the same time, Woods was hospitalized multiple times for severe anemia. Woods’s hospitalizations were classified as unpaid leave under the Family and Medical Leave Act (FMLA). Woods also requested FMLA medical leave several times surrounding her periods of hospitalization, but START denied her requests. Woods was terminated approximately three weeks after returning to work following her most recent hospitalization. Woods sued START under the FMLA, arguing that START had interfered with and retaliated against her exercise of rights under the FMLA. START countered, arguing that Woods had been fired for performance issues. At trial, START argued that the applicable causation standard for FMLA violations was the but-for standard, under which Woods would be required to prove that START would not have fired her but for her exercise of her FMLA rights. Woods countered, arguing that the applicable standard was the negative-factor standard outlined by the Department of Labor (DOL), under which Woods was required to prove only that her exercise of her FMLA rights was a motivating factor in START’s termination decision. The trial court applied the but-for causation standard and ruled for START. Woods appealed, arguing that the DOL’s negative-factor causation standard must be applied because the DOL’s interpretation of the FMLA was entitled to deference.