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Friday, September 25, 2026

General Reasons for Leave Call-Ins Satisfied FMLA Requirements - SHRM

Takeaway: The Family and Medical Leave Act (FMLA) allows employers to establish call-in requirements for employees to use FMLA leave. But an employee's reference to flare-ups, if connected to FMLA certification, may suffice to satisfy call-in requirements.

When the employee called in for leave due to flare-ups of depression and anxiety, this satisfied the Family and Medical Leave Act's (FMLA's) requirements because his doctor's FMLA certification stated he could not work during a flare-up, the 6th U.S. Circuit Court of Appeals determined.

The plaintiff started working for the car company FCA in January 2013 as an assembly-line worker at FCA's Trenton Engine Complex, then moved into a position cutting cranks for engines. FCA terminated him in September 2015 for attendance infractions but conditionally reinstated him in April 2017 for a one-year probationary period. Under the terms of the conditional reinstatement letter, FCA could terminate him if he incurred two unexcused tardies or one unexcused absence during his probationary period.

About six months after reinstatement, the plaintiff applied for intermittent FMLA leave. Sedgwick, FCA's third-party leave administrator, asked the plaintiff to provide medical documentation to support his request. His doctor submitted a medical certification form, stating that he had major recurrent depression and moderate/generalized anxiety disorder. The form noted that the plaintiff could not perform any or all job duties during a...



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