King v. St. Vincent's Hospital

Background

William “Sky” King, a member of the Alabama National Guard, accepted a three-year full-time Active Guard/Reserve (AGR) assignment and asked his civilian employer, St. Vincent’s Hospital, for a leave of absence. The hospital challenged whether federal law that guarantees leave and reemployment to service members covers such a long tour. Lower courts and several federal appeals courts disagreed about whether such leave must be “reasonable” in length before the law’s protections apply.

Reasoning

The Court looked at the text of the statute that requires employers to grant leave and to rehire service members after their military duty. The opinion found that the specific subsection at issue says nothing about a time limit, while other nearby parts of the law expressly set limits for different classes of service. Reading the statute as a whole, the Justices concluded Congress knew how to write limits when it wanted to, so no implicit duration restriction should be read into this subsection. The Court therefore reversed the appeals court that had treated a three-year absence as per se unreasonable.

Real world impact

The ruling means service members who take long AGR tours or extended training may be entitled to leave and reinstatement under the statute without a durational cutoff. Employers must apply the statute’s promise of leave and reemployment as written. The case is sent back to the lower court for further proceedings consistent with the Court’s interpretation.