Coleman v. Court of Appeals of Maryland
In brief
The Supreme Court agreed with the Fourth Circuit that states are immune from money-damages suits under the FMLA’s self-care provision.
- Where it stands
- Decided
Decided 5-4 · March 20, 2012 · Opinion by Justice Thomas
- What it’s about
- Daniel Coleman, a former Maryland Court of Appeals employee, alleged he was fired after requesting medical leave under the Family and Medical Leave Act’s self-care provision.
- Who it affects
- The decision bars money-damages suits against state governments under the FMLA’s self-care provision, including Coleman’s claim against Maryland.
Summary: written with AI from the case record.
What it's about
The Supreme Court upheld dismissal of his claim, concluding that state immunity bars damages suits under that provision.
Coleman was a former employee of Maryland’s Court of Appeals.
The FMLA provides eligible employees up to 12 weeks of job-protected leave, including leave for their own serious health condition.
Question presented
Did Congress constitutionally abrogate states' Eleventh Amendment immunity when it passed the self-care leave provision of the Family and Medical Leave Act?
What the Court decided
Holding
The judgment is affirmed. 626 F. 3d 187, affirmed. JUSTICE KENNEDY, joined by THE CHIEF JUSTICE, JUSTICE THOMAS, and JUSTICE ALITO, concluded that suits against States under the self-care provision are barred by sovereign immunity. Pp. 3 − 12.
- Result
- Affirmed
The Court's reasoning
Justice Kennedy’s opinion concluded that state immunity blocks money-damages suits under the FMLA’s self-care provision. Justice Thomas said that provision was further removed from a demonstrated pattern of state discrimination than the family-care provision.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Dissented
- Wrote an opinion
- Majority · 4joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Scaliawrote separately
From the opinions
“In other words, Congress may enact so-called prophylactic legislation that proscribes facially constitutional conduct, in order to prevent and deter unconstitutional conduct.”
What's next
The Fourth Circuit’s ruling remains in place, so Coleman’s damages claim against Maryland under the self-care provision cannot proceed.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Decision Record
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AI analysis generated: Opinion Summary
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Coleman
Opinion added: Coleman
More questions
- What does the FMLA’s self-care provision cover?
- It covers leave when an employee’s serious health condition makes the employee unable to perform the job’s functions.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.