Sheila R. Douglas v. E.G. Baldwin & Associates, Inc.
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Act's coverage requirements still govern whether a claimant can obtain relief, and an employer's voluntary leave policy does not expand statutory coverage. All 46 flagged citations have been read; the three confirmed adverse treatments are listed below.
46 later cases cite Sheila R. Douglas v. E.G. Baldwin & Associates, Inc.; 46 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Sheila R. Douglas v. E.G. Baldwin & Associates, Inc.?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Sixth Circuit rejected Douglas's jurisdictional treatment of the FMLA's employer threshold after an intervening Supreme Court decision.
Cobb v. Contract Transport, Inc. · United States Court of Appeals for the Sixth Circuit · filed
In Douglas, this Court held that “[f]or a federal court to exercise subject matter jurisdiction in a statutory scheme such as the FMLA, the defendant-company must meet the statutory definition of ‘employer.’” Id. Douglas’ reasoning applies with equal force to whether an employee meets the FMLA’s definition of “eligible employee.” Nonetheless, because intervening Supreme Court precedent has made clear that Douglas was incorrectly decided, we decline to follow Douglas and instead hold that the district court had subject-matter jurisdiction over Plaintiff’s claims.
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Declined to follow
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The Fifth Circuit treated FMLA employee numerosity as an element of a claim, rejecting the jurisdictional view it identified with Douglas.
Minard v. ITC Deltacom Communications, Inc. · United States Court of Appeals for the Fifth Circuit · filed
For these reasons, we conclude that Arbaugh has clearly rejected the conflicting view of the Courts of Appeals relied upon by ITC that employee-numerosity requirements in the FMLA and other statutes are jurisdictional rather than simply an element of a plaintiff’s claim for relief. ... Viz., Douglas v. E.G. Baldwin & Associates, Inc., 150 F.3d 604 (6th Cir. 1998)(FMLA’s definition of “employer” based on number of employees is jurisdictional)
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The court rejected Douglas's jurisdictional view when deciding whether the FMLA's employee threshold barred a claim.
Lowmack v. American Air Conditioning & Heating Solutions, LLC · United States District Court for the Middle District of Florida · filed
The first was Douglas, a Sixth Circuit opinion that reached the same result a year earlier. See Douglas v. E.G. Baldwin & Assocs., Inc., 150 F.3d 604, 608 (6th Cir. 1998). ... Arbaugh fatally undermines Douglas.
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Does this case still carry your argument?
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