Decision: In Tilley v. Kalamazoo County Road Commission, the Sixth Circuit Court of Appeals reversed a summary judgment award to the defendant employer on the plaintiff’s Family Medical Leave Act of 1993 (FMLA) claim, finding that there was a material factual dispute as to whether the employer was equitably estopped from denying that the plaintiff was an “eligible employee” under the FMLA. The lower court had granted summary judgment because the defendant did not employ at least 50 employees at, or within 75 miles of, the employee’s worksite at the time the plaintiff sought FMLA leave. However, the appellate court noted that the employer’s personnel manual made an “unambiguous and unqualified statement” that employees like plaintiff who logged 1,250 hours in the year before seeking FMLA leave were covered by the FMLA and were eligible to apply for benefits, making no mention of the requirement that they work at, or within 75 miles of, a site at which the defendant employed at least 50 employees. The court found the statement in the manual sufficient to establish a claim for equitable estoppel under the FMLA and remanded the case to the trial court for a determination whether the plaintiff reasonably relied on the statement.
Impact: This case serves as a reminder that handbook language can create binding obligations for an employer, even where the law imposes none. Employers should have their handbooks regularly reviewed by counsel to ensure that they accurately convey only the rights and benefits to which employees are entitled.