Ragsdale, an employee of Wolverine World Wide, took 30 weeks of medical leave under the company's disability leave policy while undergoing treatment for a serious health condition (cancer). During that period, Wolverine never informed her that any portion of her leave would count against her 12-week entitlement under the FMLA and therefore did not designate the leave as FMLA leave. When her 30 weeks ended, Ragsdale requested additional time off; Wolverine denied the request and terminated her employment when she could not return to work. Ragsdale sued, invoking a DOL regulation, 29 C.F.R. § 825.700(a), which provided that if an employer failed to designate leave as FMLA leave, the leave taken would not count against the employee's 12-week FMLA entitlement—thereby entitling her, she argued, to another 12 weeks of job-protected leave and reinstatement. The lower courts ruled for Wolverine, and the Supreme Court granted review.
Does the Department of Labor's regulation, which categorically prevents employers from counting leave against an employee's 12-week FMLA entitlement when the employer failed to designate that leave as FMLA leave, validly implement the FMLA; and, absent such a regulation, is an employee entitled to additional leave without showing prejudice from the employer's notice failure?
Under the FMLA, eligible employees are entitled to 12 workweeks of leave in a 12-month period for specified reasons, including a serious health condition. 29 U.S.C. § 2612(a)(1). The statute prohibits interference with the exercise of FMLA rights, § 2615, and provides remedies only for compensation, benefits, or other relief lost "by reason of" the violation, as well as equitable relief, § 2617(a)(1). The Secretary of Labor may issue regulations "necessary to carry out" the FMLA, § 2654, but may not adopt rules that alter the statute's substantive entitlements or remedial scheme. Accordingly, while employers have notice and designation obligations, an employee is entitled to relief for a notice/designation violation only upon a showing of prejudice caused by that violation; an agency may not impose an across-the-board additional-leave penalty untethered to prejudice.
The Supreme Court held that 29 C.F.R. § 825.700(a), which categorically barred employers from counting non-designated leave against the FMLA's 12-week entitlement, is invalid because it conflicts with the FMLA's text and remedial scheme. The regulation unlawfully expands employees' substantive leave entitlement and provides relief without a showing of prejudice. Ragsdale was not automatically entitled to an additional 12 weeks of FMLA leave solely due to Wolverine's failure to designate her prior leave as FMLA leave.
Text and structure of the FMLA: The statute grants a defined substantive entitlement—12 workweeks of leave in a 12-month period. The DOL rule effectively guaranteed more than 12 weeks of leave whenever an employer failed to designate prior leave as FMLA leave, thereby altering the statutory entitlement. The Court emphasized that agencies cannot by regulation extend substantive rights Congress capped by statute. Remedial scheme and prejudice requirement: The FMLA's remedies are compensatory, providing make-whole relief only for losses sustained "by reason of" the violation. This design requires a causal link between the employer's violation and the employee's harm (e.g., lost wages, benefits, or denial of reinstatement). By creating a categorical penalty that operates regardless of actual harm, § 825.700(a) departed from Congress's remedial framework. Relief for notice violations must be tailored to demonstrated prejudice, not automatic additional leave. Balance of interests and proportionality: Congress calibrated competing interests—granting job-protected leave while limiting the entitlement to 12 weeks. The categorical penalty upended that balance by punishing employers, particularly those with generous non-FMLA leave policies, with automatic additional leave regardless of circumstances. The rule's one-size-fits-all sanction failed to account for whether better notice would have changed the employee's decisions, the timing of leave, or the outcome. Administrative law constraints: Although the DOL has authority to issue regulations necessary to carry out the FMLA, that authority does not extend to rewriting the statute's substantive cap or remedial triggers. Because the regulation conflicted with the statute's text and structure, it was invalid under familiar administrative law principles governing agency deference and the Administrative Procedure Act. The Court did not reject the DOL's power to require employer notice; it rejected only the automatic, extra-leave remedy unmoored from prejudice. Application: On these principles, Ragsdale was not entitled to an additional 12 weeks of FMLA leave merely because Wolverine failed to designate her earlier leave. Any remedy required proof that the lack of designation caused her concrete harm—such as lost pay or benefits, or the loss of reinstatement—that she would not have suffered with proper notice.
Ragsdale reshaped FMLA litigation by requiring employees to prove prejudice from notice or designation violations before obtaining relief. It confirms that FMLA's 12-week entitlement is a hard cap and that remedies are compensatory, not punitive. For administrative law, the case underscores limits on agency authority: regulations cannot create categorical penalties or expand substantive statutory rights absent clear congressional authorization. Practically, employers must still satisfy FMLA notice and designation duties, but the consequence of failure is not automatic extra leave; rather, employers face liability only when their violation causes actual harm. Employees must therefore develop evidence connecting the employer's notice failure to specific losses or foregone choices (e.g., scheduling, treatment timing, or return-to-work decisions).
Ragsdale v. Wolverine World Wide, Inc. anchors FMLA litigation to the statute's 12-week entitlement and make-whole remedial scheme. By invalidating the DOL's categorical penalty for nondesignation, the Court required a showing of prejudice for relief, ensuring that remedies address actual harm rather than impose automatic sanctions.