Slaughter v. American Building Maintenance Co.
Ellis L. Slaughter, a former employee of American Building Maintenance Co. of New York (ABM), moved for partial summary judgment on his Family and Medical Leave Act (FMLA) claim and to dismiss ABM's affirmative defense of collateral estoppel. Slaughter was terminated by ABM due to excessive absences under a 'no fault' policy, stemming from recurring back pain, a condition known to ABM's predecessor. The court found that Slaughter's notice to ABM regarding his FMLA-qualifying leave was insufficient for summary judgment in his favor, as merely calling in sick did not adequately inform ABM of his FMLA-protected condition, and doctors' notes were provided with delay. However, the court granted Slaughter's motion to dismiss ABM's collateral estoppel defense, ruling that a prior arbitration decision, which upheld his termination for excessive absenteeism, did not preclude his federal statutory FMLA claim because the issues resolved were distinct and the arbitrator did not consider FMLA specifics. The motion for summary judgment was thus granted in part and denied in part.