By: Loyd Willaford and Sarah Burke
In Parker v. Metro. Gov’t of Nashville, a former Tennessee corrections officer was terminated after his FMLA leave expired. After recognizing its mistake, the sheriff’s office quickly reinstated the officer and placed him on a disability pension. The officer sued alleging both FMLA retaliation and ADA violations. The US District Court for the Middle District of Tennessee, Nashville division, found that because the officer was quickly reinstated, no adverse employment action had occurred and therefore the officer could not state a claim under either statute.