## Facts

- The Family and Medical Leave Act of 1993 (FMLA) provides eligible employees up to 12 workweeks of unpaid, job-protected leave in a 12-month period for qualifying reasons.
- Tracy Ragsdale worked for Wolverine World Wide, Inc., which offered a more generous unpaid sick-leave policy allowing up to seven months of leave.
- After being diagnosed with Hodgkin’s disease, Ragsdale began a leave of absence in February 1996 and obtained a series of 30-day extensions; she ultimately missed 30 consecutive weeks of work.
- Wolverine held Ragsdale’s position open during the leave, maintained her health benefits, and paid premiums during the first six months of her absence.
- Wolverine did not inform Ragsdale that any portion of her leave would be designated and counted as FMLA leave.
- When Ragsdale sought an additional extension beyond the company plan and requested more leave or part-time work, Wolverine denied the request and terminated her when she did not return to work.
- Ragsdale claimed entitlement to an additional 12 weeks of FMLA leave under a Department of Labor regulation providing that undesignated leave could not be counted against the employee’s 12-week FMLA entitlement.

## Issues

1. Whether 29 C.F.R. § 825.700(a), which prevented an employer from counting leave as FMLA leave absent timely designation/notice, was a valid exercise of the Secretary of Labor’s authority under the FMLA.
2. Whether the regulation could require an employer to provide up to 12 additional weeks of leave as a categorical consequence of a notice failure, even when the employee already received more than 12 weeks of leave.
3. Whether the FMLA’s remedial scheme permits automatic relief without a showing that the employee suffered prejudice from the lack of notice.

## Decision

- The Supreme Court affirmed judgment for Wolverine and held 29 C.F.R. § 825.700(a) invalid.
- The Court ruled the regulation was contrary to the FMLA and beyond the Secretary of Labor’s authority because it effectively required more than 12 weeks of FMLA-compliant leave based solely on a notice defect.
- The Court assumed, without deciding, that a notice/designation requirement could be valid, but rejected the regulation’s categorical penalty.
- Because the regulation was invalid, Ragsdale was not entitled to additional leave on that basis, and summary judgment for Wolverine was proper.
- A dissent would have upheld the regulation as a permissible enforcement mechanism for ensuring meaningful notice and protection of the 12-week entitlement.

## Legal Principles

- Agency regulations implementing the FMLA cannot expand the statute’s substantive leave entitlement beyond 12 workweeks in a 12-month period.
- The FMLA’s remedial structure links relief to actual harm: recovery is tied to losses “by reason of” a violation, direct-result monetary losses, and appropriate equitable relief, rather than automatic, irrebuttable penalties.
- A rule that awards additional leave regardless of whether the employee would have acted differently with proper notice is inconsistent with the statute because it is not connected to employee prejudice.
- Delegated rulemaking authority to carry out the FMLA does not authorize regulations that conflict with the statute’s text and remedial design by creating categorical remedies untethered to injury.

## Conclusion

The Court invalidated a Labor Department regulation that automatically granted extra FMLA leave when an employer failed to designate leave as FMLA-qualifying, holding that the FMLA does not permit categorical relief detached from employee prejudice and does not allow regulations to increase the 12-week statutory entitlement.


Ragsdale v. Wolverine World Wide, Inc., 535 U.S. 81 (2002)