In Modlendauer v. Tazewell-Pekin Consolidated Communications Center, the Seventh Circuit Court of Appeals clarified the general scope of joint-employer liability under the FMLA. Denise Moldenhauer worked for Tazcom, a non-profit entity that provided emergency 911 communications. The City of Pekin and Tazewell County created Tazcom. Moldenhauer sued Tazcom as well as the City and County for retaliation for exercising her right to take FMLA leave. Tazcom was too small to qualify as an FMLA employer; however, if the City and County were found to have a joint-employment relationship (such that City and County employees would have been added to the count), Moldenhauer would have been FMLA-eligible. The Seventh Circuit held that for a joint-employer relationship to exist, each employer must have control over the employee's working conditions. Because the City and County did not exhibit control over Moldenhauer's work or working conditions, the court held that the defendants did not jointly employ Moldenhauer.