KRISTOPHER JACKSON v. UNITED STATES POSTAL SERVICE, et al. - Articles

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KRISTOPHER JACKSON v. UNITED STATES POSTAL SERVICE, et al.

Posted by: Azya Thornton on Aug 21, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Keith Flynn, MILLER COHEN, P.L.C., Detroit, Michigan, for Appellant.

Attorneys 2: ON BRIEF: James J. Carty, UNITED STATES ATTORNEY’S OFFICE, Detroit, Michigan, for Appellees.

Judge(s): MOORE, GIBBONS, and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Flint

JULIA SMITH GIBBONS, Circuit Judge. Defendant, United States Postal Service (“USPS”), employed plaintiff Kristopher Jackson as a mail clerk. Jackson suffers from sickle cell anemia, which qualifies him for leave under the Family Medical Leave Act (“FMLA”). While working at USPS, Jackson routinely had unexcused absences—some covered by the FMLA and some not. Eventually, Jackson continued work under a Last Chance Agreement (“LCA”) which stated that Jackson would be terminated from his position if he continued to be absent from his work for days not covered under the FMLA. According to USPS, Jackson still failed to attend work numerous times for no valid reason and was thus terminated from his position for violating the terms of his LCA. Jackson then sued, claiming that several of his absences were covered by the FMLA, and that USPS’s decision to terminate him violated the FMLA and the Rehabilitation Act. USPS moved for summary judgment and the district court granted the motion in part, finding that Jackson had failed to establish a prima facie case that he qualified for the FMLA on all but one of the disputed dates. The district court also determined that Jackson failed to put USPS on notice that he required accommodations under the Rehabilitation Act. Because the district court was correct in its analysis on a few of the disputed dates and Jackson’s claims under the Rehabilitation Act but nonetheless erroneously held that an FMLA medical certification can create a hard cap on unforeseeable intermittent FMLA leave, we reverse in part and affirm in part the district court’s decision. We then remand to the district court to analyze the case in light of this opinion.

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