Law Case Review of Spangler vs. Federal Home Loan Bank of Des Moines

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Introduction Spangler v. Federal Home Loan Bank of Des Moines illustrates at least some of the difficulties for employers in dealing with FMLA regulations. Due to the Court's interpretation of the FMLA notice requirement, a manager might cope with Spangler differently depending on when that manager is allowed to manage Spangler. The Court's decision regarding Spangler was a mixed bag, agreeable and understandable in some respects but unduly burdensome on employers in other respects. In their current state, the FMLA regulations are considerably troublesome and burdensome for employers. Body As a Manager, What would you do to cope with Spangler? A manager could cope with Spangler in several ways, depending on when the manager was allowed to manage. After Spangler's call of September 16, 1998 in which she stated that she would not be in because of "depression again" (Riley, 2002), a conscientious manager would have no choice but to err on the side of caution by treating her message as a request for FMLA leave (Guerin & England, 2012, p. 298), believing that the Bank must either grant the FMLA leave or seek certification of her ongoing "serious condition" (Nelson, Spring 2005, p. 619). Despite the fact that Spangler was in no danger of becoming Employee of the Month, the Bank is held to know that: she suffered from diagnosed depression; she took leaves in the past due to her depression; and she said it was "depression again" (Riley, 2002). Consequently, at least in the

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