Coleman v. Court of Appeals of Maryland

Background

A state court employee asked for sick leave and was told he would be fired if he did not resign. He sued his state employer, saying the Family and Medical Leave Act (FMLA) entitles him to unpaid self-care leave and money damages. Lower courts found the state entity immune from money-damage suits and the case reached this Court to decide whether the FMLA’s self-care rule allows employees to recover money from States.

Reasoning

The central question was whether Congress validly took away States’ immunity so employees could get money damages for denial of self-care leave. The Court explained that Congress can only do that under Section 5 of the Fourteenth Amendment by identifying a pattern of constitutional violations and tailoring a remedy that is “congruent and proportional.” Unlike an earlier ruling that upheld the FMLA’s family-care rule, the Court found no record showing States discriminated against employees based on sex in the administration of sick or self-care leave. The opinion reviewed the legislative record, noted widespread paid sick-leave and disability coverage for state workers, rejected the petitioner’s three arguments, and concluded the self-care provision does not validly abrogate state immunity.

Real world impact

The Court affirmed that employees may not obtain money damages from an unconsenting State for violations of the FMLA’s self-care provision. A State may still waive its immunity or create a state-law remedy. Injunctive relief and enforcement actions by the Department of Labor remain available instead of individual money damages.

Dissents or concurrances

Justice Ginsburg dissented, arguing the self-care rule furthers Congress’s effort to prevent gender discrimination, and she would have allowed money-damages suits under the Fourteenth Amendment.