U.S. District Judge in the Middle District of Florida on Wednesday granted BayCare’s motion for summary judgment on Pamela Patel’s claims under the Family and Medical Leave Act, the Pregnant Workers Fairness Act, and the Pregnancy Discrimination Act, concluding a case Patel filed in August 2024.
Patel was hired in April 2022 as executive assistant to the hospital president and three other C-suite executives at BayCare’s newly constructed Wesley Chapel facility. She gave birth on March 14, 2023, and began maternity leave the same day. She received 12 weeks of FMLA leave from May 2 through July 24, 2023, plus an additional four weeks of company medical leave through August 1, 2023.
Before her leave ended, Patel emailed her supervisor requesting flexible scheduling and remote work until April 5, 2024 — more than a year after her child’s birth — citing postpartum depression, separation anxiety, and concerns about exposure to pathogens hospital facility.
BayCare’s Team Member Relations Coordinator notified Patel on July 25, 2023, that remote work could not be accommodated in her executive assistant role. The parties met on August 3, 2023, for an interactive process discussion, during which Patel submitted a list of proposed accommodations including a reverse osmosis water filtration system, IQ Air filtration units throughout the hospital, and a closed-door private office with UV and HyperHEPA filtration systems.
The court found that Patel could not explain what many of the requested items were or whether they were recommended by any physician. BayCare agreed to provide pump breaks, additional bathroom breaks, flexible scheduling for medical appointments, and the ability to bring her own water. The hospital system also offered Patel a Placement Coordinator to assist in finding a remote or alternative position at another facility.
Patel rejected the Placement Coordinator’s assistance on August 21, 2023, and never returned to work in person. BayCare hired a temporary employee on September 18, 2023, and terminated Patel on September 22, 2023.
On the FMLA claims, the court held that Patel received all 12 weeks of statutory leave plus additional non-FMLA leave, and that an employer need not reinstate an employee who takes leave beyond the 12-week FMLA entitlement. The court also found that BayCare had provided legitimate, nondiscriminatory reasons for the termination — Patel’s extended absence, her failure to cooperate with the interactive process, and her refusal to provide supporting documentation from her physician — and that Patel had not shown these reasons were pretextual.
Regarding the PWFA failure-to-accommodate claim, the court determined that Patel’s request for remote work through April 2024 was unreasonable because the essential functions of her executive assistant position — including serving as the administration suite receptionist, greeting and escorting visitors, and managing the president’s calendar — required in-person presence. The court noted that Patel’s physician had circled “no” to whether Patel had a physical or mental impairment limiting her ability to perform her job, and had only written that Patel could work from home if that was feasible.
The court further found that any breakdown in the interactive process was attributable to Patel, who rejected BayCare’s reasonable accommodation offers and declined to provide a medical questionnaire that would have clarified her limitations.
Patel’s PDA claims failed because she conceded there were no similarly situated comparators — a requirement under binding Eleventh Circuit precedent for establishing that an employer treated pregnant workers differently than non-pregnant workers with similar ability to work.
Count I, a Fair Labor Standards Act claim, was not before the court as the parties had previously settled that claim.