Gibson v. AGC Automotive Americas Co.

Ronald Gibson, an employee of AGC Automotive Americas, took leave under the Family and Medical Leave Act to care for his seriously ill wife. He was subsequently terminated for violating the company's attendance policy. Gibson filed suit in federal court in Michigan, alleging that the company interfered with his FMLA rights and retaliated against him for taking protected leave. The district court granted summary judgment in favor of AGC, finding that Gibson could not establish a causal connection or show that the stated reason for his discharge was a pretext for discrimination. On October 2, 2023, the Sixth Circuit Court of Appeals affirmed the decision, ruling that Gibson failed to present sufficient evidence to create a genuine dispute of material fact regarding pretext.

The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's grant of summary judgment in favor of AGC Automotive Americas, dismissing the case.

Whether AGC Automotive Americas unlawfully interfered with Ronald Gibson's rights under the Family and Medical Leave Act and whether his termination constituted illegal retaliation for taking protected leave.

The ruling reinforces the high evidentiary bar plaintiffs must meet to show pretext in FMLA retaliation cases, potentially making it more difficult for employees to survive summary judgment without direct evidence of discriminatory intent.