Court holds that after violation involving self-care, FMLA allows only equitable relief, and no damages, to state employees.
Ricardo Diaz and Connie Boden were employees of different Departments of the State of Michigan. Both were terminated after they sought Family Medical Leave Act accommodations for their own health care needs. Both claimed they were terminated in violation of the FMLA and sued for damages. The Sixth Circuit concluded that the 11th Amendment protected the State from damage claims based on the FMLA, if the violation related to an employee's own health. It ruled that under existing precedent, there was a public policy basis for allowing damages where there was an FMLA violation relating to an employee's family member's health, but that this policy did not apply to self-care.