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Navarro v. Pfizer Corp.

Fact questions existed as to whether pregnant adult child's high blood pressure was "disability" for which employee could seek leave under Family Medical Leave Act, and thus, summary judgment in favor of employer was improper.

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APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Jaime Pieras, Jr., Senior U.S. District Judge]

Faced with the arduous demands of legislating for an increasingly complex society, Congress often leaves interstitial details to selected administrative agencies. Congress followed this praxis when it enacted the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. �� 2601-2654, delegating implementation to the Secretary of Labor (the Secretary). See id. � 2654.

Responding to this directive, the Secretary promulgated extensive regulations. See 29 C.F.R. �� 825.100-825.800. At one point in the process, however, she caught the nearest way; in lieu of tailoring the definition of terms such as “impairment,” “major life activities,” and “substantially limits” to suit the peculiar needs of the FMLA, the Secretary simply co-opted existing definitions designed by a different agency – the Equal Employment Opportunity Commission (EEOC) – for use in connection with a different statute – the Americans with Disabilities Act (ADA), 42 U.S.C. �� 12101-12213. See 29 C.F.R. � 825.113(c)(2). Some perplexing difficulties lurk in the shadows cast by this cross-reference, including questions about the extent to which the EEOC’s informal interpretations of the borrowed definitions are binding in the FMLA context.

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