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In a case of first impression, Haybarger v. Lawrence County Adult Probation and Parole, the 3rd Circuit joined the 5th and 8th Circuits in finding individual liability for supervisors of public agencies under the Family and Medical Leave Act (FMLA). On the other side of the circuit split, the 6th and 11th Circuits have found that no such liability exists under the FMLA.

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