Ragsdale v. Wolverine World Wide, Inc.

Summary

Justice Kennedy, joined by Chief Justice Rehnquist and Justices Stevens, Scalia, and Thomas, held that the categorical penalty in 29 CFR § 825.700(a) exceeded the Secretary of Labor's authority under the FMLA. The regulation automatically awarded additional leave when an employer failed to designate previously granted leave as FMLA leave, without requiring proof of prejudice. That penalty contradicted the Act's remedial scheme and statutory framework. Because Ragsdale had received 30 weeks of leave and had not shown that the missing notice impaired her rights, the Court affirmed summary judgment for Wolverine. The Court reserved the validity of the underlying notice and designation requirements. Justice O'Connor, joined by Justices Souter, Ginsburg, and Breyer, dissented, reasoning that individualized notice and the additional-leave consequence were reasonable exercises of delegated regulatory authority; she would have reversed and remanded.