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Schaar v. Lehigh Valley Health Services Inc

Schaar v. Lehigh Valley Health Services Inc
(Petitioner) (Defendant- Appellant)
2:07-cv-04135-HSP (2010)

Action: Dismissal from job

Fact: Mrs. Schaar sued Lehigh Valley due to her dismissal from the position of hospital receptionist.

Trial Court: Shaar appealed the case to The U.S. Court of Appeals for the Third Circuit
1. Does Schaar’s lay evidence provide enough prove that she was incapacitated for more than three days?
2. Is an employee’s lay testimony, together with medical evidence, sufficiently provide reasonable basis to establish a “serious medical condition” that requires absence from the work as required by the Family and Medical Leave Act (FMLA)?

Holding: An employee’s lay evidence, supported by evidence from a medical expert, is enough to justify that the employee was incapacitated

Reason/Rule: Evidence of incapacitation is satisfied by a combination of medical and the employee’s lay proof.

Ethical Norms:
• Employee’s health and appearance at the workplace
• The right to fire employees

Analogies: Employment relations, Page 509
Missing information: Whether lay evidence alone can satisfy the requirements by FMLA
Ambiguity: The decision is right. Doctors cannot predict the outcomes of illness by 100%.

Section 2: Explanation

The action in this case involved Schaar’s illegal dismissal from her position as a medical receptionist at Lehigh Valley, where she had worked since 2002. She had sued the employer at a District Court, but the court had ruled in favor of the company. In the US court of Appeals for the Third circuit, Schaar challenged the ruling the District Court.

The facts: Schaar had worked at the Lehigh Valley three years before she was sacked in 2005. Two weeks prior to her termination, she had sought medical attention. Dr. Twaddle, one of the qualified medical experts at the facility, treated her. She had contracted urinary tract infection. The doctor gave her some drugs and a notice indicating that she would be incapacitated for two days. She left the notice at her supervisor’s door. However, her illness did not heal within two days and Schaar was incapacitated for two more days. She was not able to inform the supervisor or the doctor of her conditions. The company sacked her because of extending the sick leave by two days.
Trial court: Schaar challenged the decision of the District Court in the US Court of Appeal for the Third Circuit

Issue: The issue was to determine whether Schaar’s lay evidence, supported by evidence by a medical expert, can satisfy her claim that she was incapacitated fro three days. It involved examining whether medical evidence combined with employee’s lay evidence makes solid evidence that justifies the conditions of an employee under the FMLA in obtaining a three-day leave, which would determine the justification of Lehigh Valley to sack Schaar.

Holding: The Court of appeal saw no reason to trash the employee’s lay evidence if it is in combination with the evidence by a medical expert. Therefore, the decision of the district court was reversed.

Ethical norms: Ethically, companies should not have the right to sack or penalize their employees where lay evidence of incapacitation is supported by medical evidence. However, it is ethically wrong for employees to extend their sick leave and fail to seek additional days out of work.
Analogies: This case is detailed in a number of analytical books, including the Public law and legal environment of business.

Missing information: The ruling does not provide details on whether lay evidence by employees can stand alone to satisfy the FMLA provision for sick leave if the employee got unwell in her house prior to visiting a medical expert.

Ambiguity: The decision is right and was made based on facts. Human illness is unpredictable and can progress beyond the physician’s expectations, regardless of whether there was a medical intervention or not.

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